Many federally qualified health centers (FQHCs) in California lack access to specialty care services. But FQHCs that want to add specialty services face significant legal issues. An FQHC must fit added services within federal scope-of-project and reimbursement regulations, while also qualifying individual providers for liability protection and avoiding conflicts of interest.

This paper outlines the state and federal laws and regulations for FQHCs (and FQHC look-alikes) that govern the provision of specialty services, including:

• Federal law regarding FQHC scope of services and fees
• Malpractice insurance and the Federal Tort Claims Act (FTCA)
• Medi-Cal and Medicare reimbursement
• Referral and compensation arrangements for professional services
• California licensing and permitting requirements

This paper explains these complex rules and suggests how an FQHC can best comply with them. It includes practical checklists for health centers, targeted to each set of important issues regarding the addition of specialty services.

The complete paper is available under Document Downloads.