On January 30, 2020, the Centers for Medicare and Medicaid Services (CMS) announced its long-awaited guidance to states, “Healthy Adult Opportunities” (HAO). This initiative allows states to make drastic changes to their Medicaid programs through waivers to implement block grants and per capita caps. NACHC released a statement, submitted a further statement through the Partnership for Medicaid and is working directly with primary care associations (PCAs), like PACHC, to assess the state level impact of the HAO initiative on FQHCs. Of special note in this new guidance are the FQHC-specific provisions allowing states to waive FQHC PPS (and even alternative payment methodologies) and services via a HAO waiver. NACHC and PACHC participated in a call with CMS this week to get further information and express our concerns. We believe there is overwhelming evidence that HAO waivers would essentially lead to a cap on Medicaid spending. Shortly after release by CMS of the HAO guidelines, Pennsylvania Governor Wolf indicated his administration does not intend to seek an HAO waiver.