What are Talevski’s Implications for Community Health Centers and Their Patients? Estimating the Impact of Losing Federally Enforceable Medicaid FQHC Payment Rights

Peter Shin, Jessica Sharac, Sara Rosenbaum, and Rebecca Morris

Executive Summary

During its upcoming term, the United States Supreme Court is expected to hear arguments in Health and Hospital Corporation of Marion County v. Talevski, which could determine whether beneficiaries and health care providers will be able to seek the aid of the courts when official state actions threaten federal Medicaid rights. Among the providers that would be affected are community health centers, which have special payment protections under Medicaid’s “Federally Qualified Health Center (FQHC)” federal payment guarantee. Should health centers lose the ability to enforce FQHC rights, they would risk serious financial losses in those states that fail to honor FQHC payment rules, and these mounting revenue losses would significantly affect patient care. Using FQHC Medicaid payment data from the 2021 federal Uniform Data System, we estimate that nationwide, the potential lost revenue in one year alone could be between $643 million and $4.1 billion. Losses of this magnitude would translate into:

  • Between 500,000 and 3.2 million fewer patients served.

  • Between 4,500 and 29,000 fewer staff members.

  • Between 2 million and 13 million fewer patient visits.

Our estimates are conservative since they are based on a single year snapshot and thus do not account for ongoing financial losses over multiple years. Nor do they take into account total funding losses health centers could experience if their Medicaid benefits. Surveys of insured patients lose coverage as a result of an inability to enforce their entitlement to Primary Care Associations (PCAs) and community health centers confirm that past state Medicaid failures to comply with health centers’ full FQHC payment rights have had a serious impact on health centers’ operational capacity, including their staffing and provision of services.

The full-text data note is available here. Please see below for the accompanying infographic.

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