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OMB Pause Rescinded - Practical Advice for FQHCs Going Forward

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This week was quite a roller coaster with OMB announcements – first pausing all Federal Grants, then the block by Judge Loren Alikahn to the pause, and as of yesterday the rescinding of the pause.  We hope you have had time to decompress and digest this week’s activities.  CLC is committed to monitoring any updates to share as well as providing recommendations and support as we navigate the future. 

Updates since Tuesday, January 28: 

 CLC Recommendations – Grant Funding: 

  • Review all your grants – deadlines, requirements, allowance and unallowable expenses, current balances 

  • Identify where you may have flexibility with your grant funds to modify budgets and expenditures, especially for non-Federal grants as a back-up plan 

  • Draw down any funds that have been expended but not processed yet through PMS 

  • Ensure you have clear documentation on the uses of your grant funds 

    • Specifically, it is important to document that grant funds are not being used for the activities included in “the President’s Executive Orders, such as DEI, the green new deal, and funding nongovernmental organizations that undermine the national interest.” 

CLC Recommendations - Compliance: 

  • Continue working to meet your compliance requirements, such as FFRs, UDS, etc. 

  • Continue to prepare for OSVs that are scheduled so if they resume you are not caught off guard in a rush to prepare 

  • Monitor and document and issues with accessing portals and systems: EHB, PMS, Grants.gov 

CLC Recommendations – Revenue Cycle: 

  • Conduct financial reviews to optimize your other revenue sources, such as 340B, and efficiencies in your billing systems. 

  • Evaluate your accounts receivable balances, what types of activities can you do to accelerate cash flow? 

  • Look at trends in payer mix, reimbursement per visit by payor – are there any negative trends you need to act on? 

  • Evaluate your Medicaid PPS rate – do you have an opportunity to request an increase (depending on your State rules)? 

CLC Recommendations – Financial Strategy and Forecasting: 

  • Do not forget your routines. This is not the time to get behind on month end, cost report prep, audit processes, etc.  

  • If you are not already doing so, project your cash and create a process to be regularly updated. 

  • Identify what emergency funding sources are available to you: 

    • Line of credits 

    • Short-term bank loans 

    • Donations 

    • Hospitals affiliations, more applicable in urban areas 

  • Project out longer-term scenarios to understand the financial implications and create a contingency plan: 

    • Payer mix changes 

    • Changes in reimbursement rates for Federal programs 

    • Review staffing and determine necessity, reduced FTE, furlough, etc.  

    • Review non-salary expenses and determine the opportunity for reductions 

  • Understand your strategy and what support you will provide to employees if layoffs become necessary 

  • Tighten up your metric reporting and dashboards – are you tracking all the right things to watch for changes in operations, revenue cycle, financial? 

CLC Recommendations – Administrative and Operations: 

  • Monitor production and work to get patients in who need to be seen for follow-ups 

  • Review job titles, job descriptions, website, social media, and other organizational documentation to make updates to align with the President’s Executive Orders 

CLC Recommendations – Advocacy and Education: 

We are here to support you during this time, please reach out to us!  Many of these activities can be delegated to CLC and we have staff ready to support while you focus on other important activities. 

Phone: 509-226-1393 
E-mail: info@communitylinkconsulting.com 

Sincerely, 

Karen Creveling-Hughes, CEO