Powers’ Molly Evans and Rosie Dawn Griffin will be attending the Missouri Primary Care Association’s 2026 Annual Conference, hosted in St. Charles, Missouri.

Their presentations will address two critical legal and regulatory issues facing Missouri community health centers and Federally Qualified Health Centers (FQHCs): new Medicaid work requirements and federal fraud, abuse, and compliance obligations. Attendees will gain practical guidance on protecting patient coverage, navigating regulatory requirements, and strengthening health center compliance programs.

See session information below.

October 22, 2026

3:45 PM – 5:00 PM | Medicaid Work Requirements Under the New Interim Final Rule: What Missouri Health Centers Need to Know

Presented by Molly Evans and Rosie Dawn Griffin

Description: On June 1, 2026, CMS published an interim final rule implementing the Medicaid community engagement (work) requirement created by the 2025 federal reconciliation law, with implementation required in all 41 expansion states, including Missouri, by January 1, 2027. This session breaks down what the rule actually requires: the 80 hour per month activity standard, the categories of qualifying activities, the narrower than expected medical frailty exemption, and the shift to twice yearly eligibility redeterminations. The session closes with practical guidance for health centers on patient outreach, exemption documentation, and reducing the risk that eligible patients lose coverage for procedural rather than substantive reasons, a pattern already seen in states like Georgia and Arkansas.

Learning Objectives:

  1. Explain the core requirements of CMS’s interim final rule, including the 80-hour activity standard, qualifying activities, and the medical frailty exemption.
  2. Recognize the administrative and coverage risks documented in other states’ work requirement experience, and apply lessons learned to patient outreach and support strategies.
  3. Develop a practical checklist for helping patients document exemptions and qualifying activities to reduce the risk of procedural disenrollment.

October 23, 2026

12:15 PM – 1:15 PM | Fraud, Abuse, and Compliance Essentials for Health Centers

Presented by Molly Evans and Rosie Dawn Griffin

Description: Community health centers operate at the intersection of federal grant funding, Medicaid and Medicare billing, and complex referral relationships, which makes fraud and abuse exposure a daily operational reality rather than a theoretical risk. This session walks through the core federal fraud and abuse laws that apply to health centers, including the Anti-Kickback Statute and the False Claims Act, and connects each one to the practical situations health centers actually encounter: space and equipment arrangements with referring physicians, billing and coding practices, and cost report accuracy.

The session gives particular attention to False Claims Act exposure arising from the certifications health centers are required to make in connection with their Health Center Program federal grant awards, including compliance assurances submitted with the annual grant application and Notice of Award, Uniform Guidance certifications under 2 C.F.R. Part 200, and other programmatic certifications and assurances, any of which can give rise to False Claims Act liability under a false certification theory if inaccurate.

  1. Identify the fraud and abuse laws most likely to affect CHC operations, including common safe harbors and exceptions.
  2. Explain how the certifications and assurances health centers make in connection with their federal Health Center Program grant awards can independently give rise to False Claims Act.
  3. Describe the core elements HRSA expects to see in a health center’s compliance program. 4. Apply a framework for escalating and responding to a suspected fraud or abuse issue internally.
About MPCA

Founded in November 1984, as a private non-profit member association, we are the recognized voice of Missouri’s Community Health Centers also known as Federally Qualified Health Centers (FQHCs). We partner closely with our Community Health Centers, federal, state, local governments, and private organizations to support resources, programs, and policies that assure access to health care. To learn more, visit mo-pca.org.

About Powers’ Community Health Centers Practice

Powers’ Community Health Centers practice advises health centers and related organizations on the legal, regulatory, and operational issues that affect their work. Our team provides practical counsel on HRSA requirements, compliance, reimbursement, federal grants, 340B, privacy, and other matters critical to health center operations. To learn more about Powers’ work with Community Health Centers, visit www.powerslaw.com/practicearea/community-health-centers/.

Related Professionals
Headshot of Molly Evans in front of a blurred office hallway

Molly Evans

Principal

About Powers Law

Powers Pyles Sutter & Verville PC (“Powers”) is a Washington, D.C.-based law firm with national practices in healthcare, education, government relations, Indian tribal governments, and nonprofit law. Powers attorneys and professionals are nationally known for their extensive expertise in their practice areas and their commitment to client service. For more information, visit www.PowersLaw.com.

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