11/17/2025: Bipartisan CR Ends Government Shutdown.

On November 12, the President signed legislation that rescinds all federal employee furloughs (RIFs) after October 1, 2025, provides back pay to federal workers and restarts federal operations.

What’s in the CR for CHCs and hospitals:

  • CHC Funding: Continues at $1.4 billion through January 30, 2026 — same as last year, not adjusted for inflation
  • FQHC & RHC Medicare Telehealth Flexibilities Extended: FQHCs and RHCs can keep billing for medical telehealth as distant site providers through January 30, 2026. The in-person visit rule for behavioral health via telehealth is now delayed to January 31, 2026 (was supposed to start October 1)
  • Other Medicare Telehealth Flexibilities Extended: audio-only visits; no in-person requirement for mental health; no geographic limits or originating site restrictions

What’s not included:

  • ACA premium tax credit extension — subsidies still set to expire December 31, 2025
  • No changes to Medicaid policy in the July 4 budget bill (H.R. 1)

OPCA covers a wide range of evolving policies that impact Oregon’s Community Health Centers (CHCs). Here, we break them down by topic area with up-to-date information, provide our talking points, and collect additional partner references to help the public and our members understand the challenges ahead for CHCs.

New Content Alert – 11/10/25 – 340B Rebate Pilot 

While CHCs are busy estimating the cashflow needs, administrative costs, and lost 340B savings they will experience starting in 2026, there is a 2025 issue that could also result in significant direct costs for CHCs. If a CHC owes a contract pharmacy for any “unreplenished” units of 340B-eligible MFP drugs at COB on December 31, 2025, it need to replenish those units by buying replacements at the 2026 WAC price. In most cases, those 2026 purchases for 2025 dispenses will not be eligible for a 340B rebate, forcing the CHC to absorb the full WAC cost. (For a 60-count bottle of Eliquis 5 mg, this is the difference between the CHC paying $10 vs. $585.) To avoid this, CHCs are strongly encouraged to reach out to their contract pharmacies ASAP to discuss how to “zero out” the number of outstanding replenishment units they owe as of COB on December 31, 2025. See page 3.

RECOMMENDED ACTION ITEMS

  1. Reach out to your contract pharmacies ASAP to discuss how to “zero out” the number of outstanding replenishment units they owe as of COB on December 31, 2025, and
  2. Find all of Colleen’s resources – Toolkit, Webinar recording/slides and a 1-pager on the harms of the rebate model below
    1. Toolkit 
    2. Slides
    3. Recording
    4. One pager

Table of Contents

New Content Alert: 11/17/25 – Congress Restores Medicare Telehealth Flexibilities Through January 2026.

Message from OCHIN

The November 12 CR restores expired Medicare telehealth flexibilities through January 30, 2026 and retroactively covers claims from October 1 onward. This action supersedes CMS guidance issued last week during the lapse, when the Agency returned held claims and indicated  it would issue updated guidance if Congress acted. As such, we expect additional information on claims processing from CMS in the near future. Please consult with your legal, billing, and compliance teams to determine what approach fits your organization.

Guidance from Colleen

The CR does the following to protect telehealth reimbursement:

  • Provides legislative authority to continue Medicare reimbursement for medical services that FQHCs provide via telehealth through December 31, 2025, under the rules that have been in effect since 2020. (This provision is retroactive to Oct. 1, 2025.)
  • Delays the start of the in-person visit requirements for FQHC patients who receive behavioral health services via telehealth until Jan. 31, 2026. (This overrides the Oct. 1, 2025 start date that CMS announced in the Physician Fee Schedule reg issued on Halloween.)

 What are 330 Grants?

“The primary form of federal funding for Community Health Centers is the Health Center Program, which is authorized in Section 330 of the Public Health Services Act. More commonly known as the “330 Grant,” funding for the Health Center Program comes from a combination of discretionary funding, appropriated by Congress each year, and mandatory funding from the Community Health Center Fund (CHCF).” -NACHC

Recent developments impacting 330 grants

With the fiscal year ending on September 30, Congress is working to avoid a lapse in funding. Both chambers have considered a Continuing Resolution (CR) to extend government operations through November 21. The House passed the measure by a narrow margin (217–212), but the Senate voted to reject it. While negotiations continue, the timeline for further action remains uncertain, with reports suggesting the Senate may not revisit the issue until the eve of a potential shutdown. 

FY 2026 Federal Government Funding. The House passed, and the Senate rejected H.R. 5371 which would have funded the government at current levels from October 1 through November 21 – see full bill text. The Continuing Resolution (CR) includes several key health program extenders through November 21, 2025, including:

Health Center Impact: Both chambers left D.C. for a week-long recess after Friday’s votes. Upon their return, there will be only 2 days left to pass a CR and avoid a shutdown on 10/1. Under the current Administration, at least three career staff must approve all PMS drawdown requests before the funds can be released. There may be no career staff working in HHS as they were told that none of them would be allowed to work during a shutdown. In preparation for a possible shutdown, please consider how you will address cashflow issues if you are unable to drawdown funds from PMS during a potential Federal shutdown.

 What is 340B and why does it matter to CHCS? 

“The 340B Program enables covered entities to stretch scarce federal resources as far as possible, reaching more eligible patients and providing more comprehensive services. Manufacturers participating in Medicaid agree to provide outpatient drugs to covered entities at significantly reduced prices. Eligible health care organizations/covered entities are defined in statute and include HRSA-supported health centers and look-alikes, Ryan White clinics and State AIDS Drug Assistance programs, Medicare/Medicaid Disproportionate Share Hospitals, children’s hospitals, and other safety net providers.” (this includes CHCS) -HRSA

We recommend 340B University as a starting place to learning the fundamentals of the program. We also recommend checking out this article from the National Law Review about HRSA’s 340B rebate Pilot Program.

Recent developments related to 340B

Get OPCA’s overview on the importance of contract pharmacies within the 340B program.

340B Rebate Pilot (Updated 11/10/25)

While CHCs are busy estimating the cashflow needs, administrative costs, and lost 340B savings they will experience starting in 2026, there is a 2025 issue that could also result in significant direct costs for CHCs. If a CHC owes a contract pharmacy for any “unreplenished” units of 340B-eligible MFP drugs at COB on December 31, 2025, it need to replenish those units by buying replacements at the 2026 WAC price. In most cases, those 2026 purchases for 2025 dispenses will not be eligible for a 340B rebate, forcing the CHC to absorb the full WAC cost. (For a 60-count bottle of Eliquis 5 mg, this is the difference between the CHC paying $10 vs. $585.) To avoid this, CHCs are strongly encouraged to reach out to their contract pharmacies ASAP to discuss how to “zero out” the number of outstanding replenishment units they owe as of COB on December 31, 2025. See page 3.

RECOMMENDED ACTION ITEMS

  1. Reach out to your contract pharmacies ASAP to discuss how to “zero out” the number of outstanding replenishment units they owe as of COB on December 31, 2025, and
  2. Find all of Colleen’s resources – Toolkit, Webinar recording/slides and a 1-pager on the harms of the rebate model below
    1. Toolkit 
    2. Slides
    3. Recording
    4. One pager

What are CCO rates?

“The Oregon Health Authority (OHA) contracts with coordinated care organizations or CCOs. CCOs manage and deliver health care for most people eligible for the Oregon Health Plan (OHP). OHA pays CCOs to cover these individuals with capitation rates.

  • Capitation rates are a predetermined payment that depends on the individual’s OHP eligibility status.
  • OHA pays capitation rates to CCOs on a monthly basis dependent on enrollment.

OHA’s contracted actuaries develop and certify CCO capitation rates on a yearly basis. Federal and state regulations govern the process and methodology used to develop capitation rates.” -OHA

Recent CCO rate setting news

OHA is exploring strategies to boost CCO managed care rates because the system is currently underfunded. OHA proposed to reallocate a percentage of Quality Pool funds into the CCO rates, which will reduce available Quality Pool Resources for Oregon’s FQHCs. Learn more from the Lund Report.

Get OPCA’s Talking Points on this issue. 

Read public testimony submitted on QIP to the CCO Metrics and Scoring Committee (from a broad coalition of partners, OPCA among them.)

 What is H.R.1? 

“The One Big Beautiful Bill Act of 2025 (OBBBA), the massive budget reconciliation bill implementing many of the administration’s top legislative priorities, was signed into law (Public Law 119-21) on July 4, 2025. The law includes significant funding cuts and policy changes to Medicaid and the Health Insurance Marketplaces, Medicare physician payment and medical student loans, among other health care related items.” -American Medical Association

Recent H.R.1 news

We are collecting and curating resources to help CHCs prepare for H.R.1’s impact in Oregon. We recommend checking out:

Got more questions? Please contact Danielle Sobel (dsobel@orpca.org) with any pressing questions.

Get OPCA’s H.R.1 Talking Points

H.R.1 and RHTF

Recently, OPCA and the Network submitted public comments to the Oregon Health Authority on our ideas for how to utilize federal funds from the Rural Health Transformation Fund (RHTF).

Check out the unabridged version of OPCA’s ideas for RHTF.

Check out the Network’s ideas for RHTF.

OPCA compiled these suggestions with input from NACHC and Colleen Meiman.

What is Medicaid?

“Medicaid is the primary program providing comprehensive coverage of health care and long-term services and supports to about 80 million low-income people in the United States. Medicaid accounts for one-sixth of health care spending (and half of spending for long-term services and supports) and a large share of state budgets.” -KFF

Recent Medicaid changes

Check out OPCA’s talking points on the issue.

What is PRWORA?

On July 14, 2025, the U.S. Department of Health and Human Services (HHS) issued a notice of a policy change to update the definition of “federal public benefits” as outlined in the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA) to add an additional 13 programs to the 31 programs considered “federal public benefits” that are restricted to individuals with a “qualified” immigration status. (…) This change bars many groups of lawfully present immigrants as well as undocumented immigrants from accessing many health care, educational, and other social services and will likely have negative impacts on the health and well-being of immigrant families due to more limited access to services as well as confusion and fear about using services. (…) This policy change was expected to take effect immediately upon publication of the notice in the federal register on July 14, 2025, although it provided for a 30-day comment period. However, the HHS has agreed to delay implementation until September 11, 2025, following court orders.” -KFF

Recent PRWORA updates

Oregon State Government is a part of the lawsuit against the federal government, and due to the judge’s ruling, Oregon is exempt, at this time, from compliance until an official ruling on the case. Oregon was one of 22 states plus DC that sued and won this temporary injunction on implementing changes to the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA); for health centers, the changes identified in the proposed rules included how “Federal public benefits” were defined and programs they applied to (including the health center program).
NOTE: One state reported that a CHC has received two denial notifications from CMS for Medicare claims based on the individual being “not lawfully present.” PRWORA does provide safe harbor exemptions for nonprofit entities having to validate citizenship status, but also requires action once status is known. In this case, CMS is providing the notification. Health Centers are unique in that they are statutorily required to provide care to the individual regardless. One PCA noted the significant challenges that may occur if people with ESRD or other life-saving medical needs are denied coverage.

Check out OPCA’s letter to Robert F. Kennedy Jr. with OPCA’s thoughts on interpreting the “Federal Public Benefit” rule. 

11/17/25 Update: Congress Restores Medicare Telehealth Flexibilities Through January 2026.

Message from OCHIN

The November 12 CR restores expired Medicare telehealth flexibilities through January 30, 2026 and retroactively covers claims from October 1 onward. This action supersedes CMS guidance issued last week during the lapse, when the Agency returned held claims and indicated  it would issue updated guidance if Congress acted. As such, we expect additional information on claims processing from CMS in the near future. Please consult with your legal, billing, and compliance teams to determine what approach fits your organization.

Guidance from Colleen

The CR does the following to protect telehealth reimbursement:

  • Provides legislative authority to continue Medicare reimbursement for medical services that FQHCs provide via telehealth through December 31, 2025, under the rules that have been in effect since 2020. (This provision is retroactive to Oct. 1, 2025.)
  • Delays the start of the in-person visit requirements for FQHC patients who receive behavioral health services via telehealth until Jan. 31, 2026. (This overrides the Oct. 1, 2025 start date that CMS announced in the Physician Fee Schedule reg issued on Halloween.)

Get OPCA’s October 2025 Guidance on Telehealth Appointments During the Federal Government Shutdown