Can tribal clinics be treated as Federally Qualified Health Centers (FQHCs) for the Medicaid EHR Incentive Program?
A 1996 memorandum of agreement (MOA) between CMS and Indian Health Services (IHS) addressed the roles and responsibilities in implementing payment policies covering American Indian and Alaska Native (Al/AN) individuals through health care facilities owned and operated by AI/AN tribes and tribal organizations (“tribal clinics”) with funding authorized by the Indian Self-Determination and Education Assistance Act (Public Law 93-638, as amended). Under this 1996 MOA, tribal clinics may choose between being reimbursed for health care services as an IHS facility or an FQHC. If tribal clinics are reimbursed under the Medicaid program at the state’s FQHC reimbursement rate, these clinics will be treated as FQHCs for the Medicaid EHR Incentive Program (regardless of section 330 certification). If tribal clinics elect to be reimbursed as an IHS facility (or any method other than the FQHC reimbursement rate), they will not be treated as FQHCs for this program.
Related Questions
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