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Policy Priorities

CHAD tracks closely policy and legislative updates, changes and issues at both the federal and state levels and works with congressional and state officials to ensure that health centers and their patients are represented throughout the legislative and policy making process.

At the core of FQHC policy priorities is protecting access to quality health care for all Dakotans, especially the rural, uninsured and underserved populations. Another core priority is ensuring health coverage for all to foster healthy communities and sustain the overall operations and growth of health centers across the Dakotas.

Federal Advocacy

Legislation and policymaking at the federal level significantly impact federally qualified health centers (FQHCs), especially in the areas of funding and program development. That’s why CHAD’s policy team works closely with its member health centers and health care partners across the Dakotas to develop policy priorities and convey those priorities to congressional leaders and their staff. CHAD connects on a regular basis with congressional members and their offices to keep them apprised of issues impacting FQHCs and their patients and to encourage them to take action on key health care legislation and policies.

Federal Policy Priorities

The Dakotas’ community health centers and South Dakota Urban Indian Health provided primary care, behavioral health services, and dental care to over 136,000 Dakotans in 2021. They demonstrated that communities could improve health, reduce health inequities, generate taxpayer savings, and effectively address a multitude of costly and significant public health problems, including epidemics of flu and coronavirus, HIV/AIDS, substance use disorders, maternal mortality, veterans’ access to care, and natural disasters. 

To continue their important work and mission, health centers need increased pharmacy access for underserved patients, support for health centers’ telehealth services, investment in workforce, and strong and stable funding. Health centers want to continue to work in partnership with Congress to address the following issues. 

Increasing Pharmacy Access for Underserved Patients

Providing access to a full range of affordable, comprehensive services, including pharmacy services, is a key component of the community health center model. The savings from the 340B program must be reinvested into health center activities and are integral to health centers’ ability to sustain ongoing operations. In fact, many health centers report that due to their slim operating margins, without the savings from the 340B program, they would be severely limited in their ability to support many of their core services and activities for their patients. 

  • Make it explicitly clear that 340B covered entities are entitled to purchase all drug manufacturers’ covered outpatient drugs at 340B pricing for eligible patients through each covered entity’s contract pharmacies. 
  • Cosponsor the PROTECT 340B Act (HR 4390), from Reps. David McKinley (R-WV) and Abigail Spanberger (D-VA) to prohibit pharmaceutical benefit managers (PBMs) and insurers from engaging in discriminatory contracting practices or “pick-pocketing” 340B savings from health centers. 

Expand CHC Telehealth Opportunities

All community health centers in the Dakotas are utilizing telehealth to meet their patients’ needs. Telehealth services help address pandemic, geographic, economic, transportation, and linguistic barriers to health care access. Because CHCs are required to offer comprehensive services in areas of high need, including sparsely populated rural areas, health centers are pioneering the use of telehealth to expand access to quality health care services.  

  • Support legislative and regulatory efforts to ensure an extension of the public health emergency (PHE) telehealth flexibilities, ideally through a permanent policy change or at least two years to provide certainty for health centers. 

  • Support for the CONNECT for Health Act (H.R. 2903/S. 1512) and Protecting Access to Post-COVID-19 Telehealth Act (H.R. 366). These bills modernize Medicare policy by recognizing health centers as “distant sites” and removing “originating site” restrictions, allowing telehealth coverage wherever the patient or provider is located. These bills also allow telehealth services to be reimbursed equally to an in-person visit. 


Community health centers depend upon a network of over 255,000 clinicians, providers, and staff to deliver on the promise of affordable and accessible health care. Long-term investments in the nation’s primary care workforce are needed to achieve the cost-savings the country needs and to ensure health centers can keep pace with the growing and changing health needs in their communities. Severe workforce shortages and growing salary gaps make it difficult for health centers to recruit and retain an integrated, multi-disciplinary workforce to provide high-quality care. The National Health Service Corps (NHSC) and other federal workforce programs are critical to our ability to recruit providers to communities that need them. We appreciate the funding provided in the American Rescue Plan Act to address workforce shortages caused by the pandemic. Continued federal investment is essential to broadening the workforce pipelines health centers depend on to provide care to patients.  

  • Support $2 billion for the NHSC and $500 million for the Nurse Corps Loan Repayment Program. 
  • Support robust FY22 and FY23 appropriations funding for all primary care workforce programs, including the Title VII Health Professions and Title VIII Nursing Workforce Development programs. 

Support Community Health Centers

We appreciate American Rescue Plan Act funding allocated to health centers to respond to COVID-19 and additional funding for the primary care workforce and vaccine distribution. The COVID-19 pandemic has highlighted the inequities of the health care system for our rural, minority, veteran, senior, and homeless communities. Now more than ever, health centers have been essential stakeholders in the public health system – providing much-needed primary and behavioral health services during the throes of an international pandemic. In 2022, we are looking to Congress to maintain the base funding for CHCs and invest in future growth for the program. 

  • Support at least $2 billion in Health Center Capital Funding for the alternation, renovation, remodeling, expansion, construction, and other capital improvement costs so health centers can continue to meet the health needs of their growing patient populations and the communities they serve.

Protecting Volunteer Health Professionals’ Ability to Serve at Community Health Centers

Volunteer health professionals (VHPs) provide invaluable workforce support to community health centers and their patients. The Federal Tort Claims Act (FTCA) currently provides medical malpractice coverage for these volunteers. However, this protection expires on October 1, 2022. Severe primary care workforce shortages both before and during the COVID-19 pandemic highlight the critical urgency for unpaid medical professional volunteers to receive continued FTCA medical malpractice protection.  

  • Permanently extend the Federal Torts Claim Act (FTCA) coverage for community health center VHPs. The extension is currently included in the bipartisan Senate HELP discussion draft of the Prepare for and Respond to Existing Viruses, Emerging New Threats (PREVENT) Pandemics Act.  

North Dakota Advocacy

Supporting the work and mission of community health centers and protecting access to health care for all North Dakotans are principles at the center of CHAD’s advocacy efforts. Our team works closely with member health centers and health care partners across North Dakota to monitor legislation, develop policy priorities, and engage lawmakers and other state and local officials. CHAD is committed to ensuring that CHCs and their patients are represented throughout the policymaking process.

North Dakota Policy Priorities

North Dakota’s legislature meets every two years in Bismarck. During the 2023 legislative session, CHAD is working to promote policy priorities for community health centers and their patients. Those priorities included support Medicaid payment reform, state investment of CHCs, and expanding dental benefits, community health workers, and childcare investment.

Medicaid Payment Reform

North Dakota Medicaid and community health centers (CHCs) have a shared goal of improving health outcomes for Medicaid beneficiaries. We need a payment model that supports an approach to care proven to improve quality and lower total costs. CHCs are encouraging lawmakers to develop a Medicaid payment model that:

  • Supports the types of high-value services that have been shown to improve outcomes, including care coordination, health promotion, help with transitions of care, and assessment of social risk factors to make high-impact referrals to needed community-based services;
  • Incorporates evidence-based quality measures and provides financial incentives for providers when quality and utilization goals are met;
  • Aligns with existing payment reform models such as patient-centered medical home (PCMH) and Blue Cross Blue Shield of North Dakota’s BlueAlliance program; and,
  • Eliminates the counterproductive aspect of the primary care case management program that leads to Medicaid denying needed (and high-value) primary care services. Medicaid’s current refusal to pay for primary care services when the patient sees a provider that Medicaid has not designated as their primary care provider (PCP) leads to unnecessary emergency room visits and large financial losses for CHCs and others trying to serve patients in the community.


Community health centers provide comprehensive care for patients across North Dakota, including dental care. Evidence connects healthy mouths with a healthy body. For example, a 2017 study of people with diabetes shows that medical costs are $1,799 lower for patients who have received appropriate oral health care than those who have not. Insufficient dental coverage can result in additional emergency room visits, which can adversely affect blood pressure, diabetes management, and respiratory health.

  • Extend dental benefits to ALL North Dakota Medicaid recipients, including individuals covered by Medicaid expansion.

State Investment in Community Health Centers

Community health centers (CHCs) in North Dakota play an integral role in our state’s health care system serving over 36,000 patients a year. Twenty-nine states currently appropriate state resources to CHCs to support their mission of providing care for underserved and vulnerable populations. North Dakota CHCs would like to be added to this list.

We ask you to consider allocating $2 million in state resources to CHCs to sustain and grow their ability to serve vulnerable and underserved populations in the state. They would use the resources to meet the following goals:

  • Reduce emergency room visits and hospitalizations for Medicaid beneficiaries and the uninsured;
  • Sustain a needed community resource for the most vulnerable;
  • Respond to workforce challenges and shortages;
  • Make health IT investments that support quality improvement; and,
  • Overcome barriers to health in underserved communities to support access to healthy food and affordable housing, sustain outreach, translation, transportation, and other non-billable services.

Community Health Workers

Community health workers (CHWs) are trained front-line health care workers with social and relational ties to the communities they serve, who work as community-based extensions of health care services. CHWs could expand access to health care in North Dakota, reduce health care costs, and improve health outcomes for North Dakotas. When integrated with primary health care, CHWs can enhance team-based, patient-centered care by complementing the work of health care professionals. CHWs help primary care providers understand the real problems that clients face daily. They can help build trust between patients and their health care teams to solve problems and figure out how to implement their clinical care plans.

As health systems work on strategies to improve health outcomes, reduce health care costs, and reduce health inequities, North Dakota can consider implementing laws to establish sustainable CHW programs.

  • Create a supportive infrastructure for CHW programs, addressing professional identity, education and training, regulation, and medical assistance reimbursement.

Invest In Childcare to Provide Accessible, High-Quality, and Affordable Care

Childcare is, of course, a critical component of a thriving economy. Access to affordable childcare is essential for parents to stay in the workforce and an important element of recruiting workers to our communities. On average, working families in North Dakota spend 13% of their family budget on infant childcare. At the same time, childcare businesses struggle to stay open, and childcare workers earn $24,150 if working full-time, barely hovering above the poverty level for a family of three.

  • Support increased pay for childcare workers, adjust income guidelines to provide more families with childcare assistance, extend childcare stabilization grants, and expand Head Start and Early Head Start programs.

South Dakota Advocacy

Supporting the work and mission of health centers and protecting access to health care for all South Dakotans are principles at the center of CHAD’s advocacy efforts. Our team works closely with member health centers and health care partners across South Dakota to monitor legislation, develop policy priorities, and engage lawmakers and other state and local officials. CHAD is committed to ensuring that health centers and their patients are represented throughout the policymaking process.

South Dakota Policy Priorities

South Dakota’s legislature meets annually in Pierre. The 2023 legislative session began on January 10, 2023. During the session, CHAD will monitor  health care-related legislation while supporting and promoting four key policy priorities:

Workforce – Development and Recruitment of Health Care Professionals

Health care workforce solutions in rural communities continue to need additional investment. One promising program is the State Loan Repayment Program. This program allows states to set local priorities for loan repayment for health professionals who work in health professional shortage areas. We appreciate that the South Dakota Department of Health recently took advantage of these funds to support the recruitment of health professionals.

We know that the demand for this type of program is high, and we would encourage additional support for these programs to meet that demand. Other solutions include strengthening existing health care workforce pipeline programs, investing in developing new pipeline programs, and expanding investment in training programs.

Workforce – Optimal Team Practice Legislation

Community health centers and South Dakota Urban Indian Health rely on the professionalism and expertise of physician’s assistants (PAs) and other advanced practice providers to meet the needs of the rural and urban communities they serve. The evolving medical practice environment requires flexibility in the composition of teams to meet the diverse needs of patients. The manner in which PAs and physicians practice together should not be determined at the legislative or regulatory level. Instead, that determination should be made by the practice in the best interest of the patients and communities they serve. Current requirements diminish team flexibility and limit patient access to care without improving patient safety.

340b Protect Access to Affordable Medication through the 340b Program

Community health centers and South Dakota Urban Indian Health are working to provide a full range of affordable health care services, including pharmacy. One tool we use to serve that mission is the 340B drug pricing program. This program was established in 1992 to offer more affordable pricing to patients served by rural and safety net providers.

Health centers exemplify the type of safety net program the 340B program was intended to support. By law, all health centers:

  • Serve only health professional shortage areas;
  • Ensure that all patients can access the full range of services they provide, regardless of insurance status, income, or ability to pay; and,
  • Are required to reinvest all 340B savings into federally approved activities to advance their charitable mission of ensuring access to care for the underserved.

We are asking the state to protect this important program that offers all health center patients access to affordable prescription medications. Various manufacturers have threatened the loss of drug discounts for drugs shipped to contract pharmacies that administer 340B drugs on behalf of some of our state’s most impactful providers. This targeting of contract pharmacies is especially troubling in rural communities, where local pharmacies are already struggling to stay afloat.

Medicaid Expansion Implementation

In South Dakota, Medicaid will expand the program in July 2023. Other states that have expanded their Medicaid program have seen improved access to care, improved health outcomes, and reduced uncompensated care, which makes health care more affordable for everyone.

To ensure implementation of South Dakota Medicaid expansion is effective, we ask that you prioritize with the Department of Social Services these recommendations:

  • Develop a Medicaid Expansion Advisory Committee, or sub-committee of the Medicaid Advisory Committee, to facilitate and enhance communication with providers, health systems, and patients that this will impact;
  • Support Governor Noem’s budget request to increase staff and technology in the Medicaid program; and,
  • Provide funding to organizations that are a trusted voice in community health care and health insurance coverage to do specific outreach to new Medicaid patients.