CLC remains dedicated to keeping you informed with the latest updates, offering recommendations, and supporting you as we move forward together. Here’s a recap of last week’s activities:
Updates since Tuesday, January 31:
January 31 – HRSA sent an e-mail to grantees that was then rescinded on 2/6/2025
February 3 – Lawsuit was filed by Federal Court of Maryland in Baltimore – against the president for trying to take powers of the purse from Congress
February 3 – “Temporary Restraining Order Against OMB Memorandum M-25-13” was issued
February 4 – Feldesman hosted a webinar 2/4/2025 – What Grantees Need to Know – CLC staff attended
February 5 – 8: NACHC hosted the 2025 P&I Forum. It was well attended by FQHC leaders, FQHC vendors, and representatives from Congress. HRSA staff were not in attendance.
February 5 – HRSA removed Compliance Manual Chapter 20, Board Composition, per an Executive Order to revise and remove the term “sex.”
February 7 – HRSA issued an updated draft of the “Health Center Program Scope of Project Policy Manual” – comments are due to HRSA 2/10/2025 by 11:59 pm ET.
February 7 – the pause on OSVs is extended to March 31, 2025.
What We Are Hearing from Clients and our Networks:
Numerous health centers nationwide have not yet received payments from PMS.
There have been outages in the PMS and EHB systems.
Several FQHCs and FQHC-LALs have been forced to lay off staff and, in some cases, temporarily or permanently close sites.
There has been a decline in patient visits attributable to migrants’ concern.
FQHCs and FQHC-LALs have managed to conduct discussions with their Project Officers.
Key Points from February 4, 2025 Webinar Hosted by Feldesman:
Federal Directives and Compliance: While Executive Orders and federal actions may not hold legal status, Community Health Centers (CHCs) might have to adhere to them to maintain federal funding until legal proceedings are resolved.
Judicial Outlook and Administrative Leverage: Legal challenges against these orders are likely to succeed. However, in the interim, the executive branch may enforce compliance through:
New grant conditions are supposedly coming out in the next couple of weeks that will require adherence to non-discrimination laws
These conditions may include “false claims” penalties that would create real issues for CHCs attesting to their grant compliance inaccurately
Budgetary Implications: With the current budget continuing resolution set to expire in March, a majority in Congress could embed similar restrictions in the next budget cycle, potentially enhancing the enforceability of these grant conditions.
Strategic Review and Response: It's crucial for health centers to audit their programs and communications for potential issues under these new regulations. Decisions on whether to comply or resist depend on short-term strategic considerations.
Drawdown and Compliance Concerns: CHCs under drawdown restrictions should exercise caution, especially when making Payment Management System (PMS) requests that could trigger compliance reviews due to the potential lack of live staff oversight.
If you are NOT receiving payments from PMS - CLC Recommendations:
Contact your Grants Manager to discuss and resolve the issue.
Reach out to your legislator for advocacy and support.
Through your legal counsel, file a formal complaint with the Department of Justice.
Keep detailed records of all communications with PMS and HRSA.
CLC Recommendations for Immediate Action:
Compliance and Monitoring
Ensure Ongoing Compliance: Continue to meet all regulatory requirements, including FFRs, UDS, and other mandatory reports.
System Accessibility Monitoring: Vigilantly monitor and document any issues encountered with accessing essential online platforms such as the Electronic Handbooks (EHB), Payment Management System (PMS), and Grants.gov.
Board Communication
Enhanced Board Engagement: Keep your Board of Directors well-informed through regular updates. Consider convening an ad-hoc meeting if necessary to discuss critical issues and field questions.
Strategic Crisis Management
Establish a Crisis Response Team: Form a task force that includes at least one Board member to:
Assess Impact: Forecast potential impacts of current events on your operations.
Emergency Funding: Identify and plan for emergency funding sources.
Employee Support Strategy: Develop a strategy for supporting employees, including contingency plans for layoffs if required.
Strategic Adjustments: Revisit and adjust your strategic plan to set new priorities, defer projects, and pivot operations to meet immediate organizational needs.
Communication Strategy
Internal Communication:
Regular Updates: Implement regular scheduled updates via email, intranet, or virtual meetings to keep staff informed of any changes and developments. This ensures transparency and reduces uncertainty.
Feedback Channels: Establish open channels where employees can voice concerns, ask questions, and provide feedback. This could be through anonymous surveys, suggestion boxes, or scheduled Q&A sessions with leadership.
External Communication:
Stakeholder Briefings: Regularly update external stakeholders, including funders, community partners, and service recipients, on the organization's status and response strategies via newsletters, dedicated web pages, or social media updates.
Transparent Reporting: Share challenges and successes in dealing with the crisis through public reports or briefings. This transparency can build trust and support from the community and stakeholders.
Community Engagement: Enhance engagement with the community through virtual town hall meetings or community forums, allowing for direct communication and support to those affected by the crisis.
CLC Recommendations – Monitor Upcoming Activities and Important Deadlines:
Engage with Social Media: If you've been less active, now is a good time to reconnect, particularly on LinkedIn where many industry leaders share valuable insights. Consider following these profiles for relevant updates:
Federal Budget Watch: Keep an eye on the Federal Continuing Resolution, which funds the government until March 14, 2025. A government shutdown is possible if a new budget for FY 2025 isn't approved by Congress.
Leadership Update: The nomination for the HHS Secretary is set to advance to the Senate on Tuesday, February 11, 2025.
340B Program Recertification: Ensure your annual 340B recertification is completed between February 10 and March 10, 2025.
UDS Submission Deadline: Don’t miss the deadline for submitting your UDS. Ensure it is completed by 11:59 PM EST on Saturday, February 15, 2025.
Potential Effects to Medicaid: There are concerns about changes to Medicaid policy and funding cuts. It is important to monitor this and know what the potential effects are on your organization.
We are here to support you, so please don't hesitate to contact us! Many tasks can be entrusted to CLC, where our team is prepared to assist, allowing you to concentrate on other crucial matters.
Phone: 509-226-1393
E-mail: info@communitylinkconsulting.com
Sincerely,
Karen Creveling-Hughes, CEO