Centers of Excellence Changes and Impact on Federally Qualified Health Centers

Ten Pennsylvania FQHCs are substance use disorder Centers of Excellence (COE). Recent changes to the program have raised some questions, including the question PACHC posed to Department of Human Services (DHS) on whether, under the state plan amendment DHS is submitting to CMS, case managers will be considered as eligible FQHC providers. We want to ensure that, due to the uniqueness of FQHCs and FQHC billing methodology, our health centers are being compensated fairly for the services they are providing to patients.


Per DHS: In short, the answer is that, because the FQHC-COEs bill for the G9012 procedure code under the 13-digit MPI associated with their 232 Opioid Center of Excellence provider specialty enrollment, rather than their MPI associated with the FQHC enrollment, and they are paid the $277.22 PMPM rather than their PPS for G9012 code services, case managers may perform the G9012 service that is billed under the 232 provider number, regardless of whether those case managers are considered eligible FQHC providers for PPS purposes.


You either bill as an FQHC or a COE, which are two different entities. For enrollment purposes, the provider specialty codes are different, and you are not “an FQHC that is also a COE.” If acting and billing as an FQHC, then the eligible practitioner SPA page and Appendix E handbook/PPS rules apply. If acting and billing as a COE, then the case manager policies and G9012 payment methodology apply.


PACHC is hosting a call on March 2 for FQHC-COEs to meet with DHS on the changes to COE payment methodology and have the opportunity to ask any additional questions. Please contact Amy Williams, PACHC’s Program Specialist for Behavioral Health and Substance Use Disorder, with questions.