James Hennessy


This Article addresses the future of Federally Qualified Health Centers (FQHCs) in an entirely reformed primary care landscape under the Affordable Care Act (ACA). Given health centers’ ability to fill crucial access gaps that will remain after health reform, FQHCs stand to undertake an increased role and are thus vital to the implementation of the ACA. Yet questions remain as to whether current FQHCs are capable of taking on an increased demand for services resulting from ACA expansion. Health centers are already busy, and more patients are coming as many burdens of health reform will inevitably fall on their shoulders. FQHCs have grown in capacity and number over time, but such development has varied considerably. Because increased funding will not be sufficient to bolster the current primary care network, FQHC qualification requirements must adapt to a new health care environment.

This Article specifically targets Medically Underserved Area (MUA) and Medically Underserved Population (MUP) designations as improper threshold requirements for FQHC status. MUA/MUP designations—prerequisites to FQHC qualification—are increasingly imprecise, outdated, and overly-complex. The MUA/MUP status requirements have barred many deserving areas from creating FQHCs, and they must be changed in order for centers to meet their critical obligations in light of an unprecedented growth in demand for health services.

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