Relating to expedited credentialing of certain federally qualified health center providers by Medicaid managed care organizations.

Contracts

• Provider Employment Agreements: FQHCs must amend offer letters and employment contracts to require new hires to submit all credentialing documentation before their start date. The expedited payment clock cannot start until the MCO receives a "complete" application.
• MCO Payer Contracts: While state law overrides conflicting contract terms, MCOs may issue unilateral amendments to align provider manuals with HB3151. Legal counsel should review these for any non-statutory restrictions attempted by the payer.

Hiring/Training

• Credentialing Staff: Retrain staff to submit applications to MCOs on the *exact day* of hire or Medicaid enrollment. Delays in submission now directly equate to lost revenue.
• Billing Departments: Update billing software to release claims for new providers immediately upon application submission. Do not hold these claims in a "pending" queue.

Reporting & Record-Keeping

• Submission Receipts: Implement a strict protocol for retaining digital receipts/timestamps of application submissions. This timestamp is your legal proof for the start of retroactive payment eligibility.
• Provisional Ledgers: Finance teams must track revenue generated by providers in the "expedited" phase separately. These funds are conditional and subject to recoupment if credentialing is ultimately denied.

Fees & Costs

• Clawback Reserves: There are no new state fees. However, FQHCs must maintain liquidity to repay MCOs if a provider fails the final credentialing review. The law authorizes MCOs to recover the difference between in-network and out-of-network rates (or the full amount) in these cases.