The Funding Bill Passed but Health Centers Should Not Relax

Yesterday, the President signed a continuing resolution (CR) that allows the government to open through December 11. Though this signals the end of the government shutdown dominating the headlines, community health centers remain in an uncomfortable position because the CR moves the hardest funding question of the year into the shortest and most crowded legislative window of the year.

What the CR does

The CR funds federal agencies at fiscal 2026 levels through December 11. That covers the discretionary side of health center funding, with roughly 30% of the federal grant dollars that flow through Section 330. What the CR does not address is the Community Health Center Fund, which supplies about 70% of federal grant funding to health centers. Its current authorization ends December 31, 2026 and nothing Congress has passed this year extends past that date.

In July the House Energy and Commerce Committee passed the Lower Costs, More Transparency Act, which would add $500 million for behavioral health and $250 million for nutrition services at health centers over fiscal years 2027 and 2028. After reading the bill, it is important to note that it does not reauthorize the base Fund, and the bill still needs to pass through the House Ways and Means and Education and Workforce Committees before it can reach the House floor. So health centers should not be under the impression that their funding has been taken care of, the funding issue still remains.

Why December is more difficult than September

The CR expires on December 11, and the Community Health Center Fund expires December 31. The Medicaid community engagement requirement takes effect in most states January 1, 2027, which includes the 80 hours a month of qualifying activity verified at application and renewal.

All three of these land after the November 3 midterm elections, in a lame-duck session where leadership will be negotiating a full-year appropriations package, a health extenders package, and whatever else did not get done. Health center funding has historically been carried inside those year-end vehicles rather than on its own, but they should be prepared in the event that this does not happen this year. For example, the Fund lapsed on September 30, 2017 and was not restored until the Bipartisan Budget Act of February 2018. Health centers ran on uncertainty for roughly five months. In 2019, Congress managed the deadline with a two-month bridge and last year the authorization was carried from September 30, 2025 to January 30, 2026 by the resolution that ended a 43-day shutdown, and then extended only to December 2026 by the February omnibus. Short bridges have become the pattern, and each bridge is negotiated under time pressure by a small number of people.

The January 1 Medicaid date compounds the problem because roughly half of health center patients are covered by Medicaid. The Congressional Budget Office projects more than five million people losing coverage as after the work requirements take place, and the early experience in Nebraska and Montana, which chose to implement ahead of the federal date, has already produced reporting confusion. A health center could open January 2027 with its largest federal grant unextended and its largest payer shedding patients in the same week.

What a health center should do before Thanksgiving

• Know your exposure in dollars and not just percentages — Pull the Section 330 award, isolate the portion that flows from the Fund, and put it next to days of cash on hand. NACHC has reported that 42% of health centers hold 90 days or less of cash reserves. If that describes your organization, the board should see a written contingency before the December package is drafted, not after.

• Put your patient numbers in front of your delegation now — The December package will be negotiated by leadership and the committees of jurisdiction. In the House that is the Energy and Commerce Committee, and within it the Health Subcommittee. Members respond to constituent numbers from their own district far more than to national totals. A one-page district profile showing patients served, jobs supported, and the share of federal grant revenue at risk is more useful to a congressional office in October than a fly-in in December.

• Watch the verification design in your state, not just the exemption list — Under the interim final rule, states must use data already available to them before asking beneficiaries for documentation, and states decide which data sources qualify. Health centers hold employment, caregiving, and medical frailty information about their patients that state systems often do not. Whether a state treats provider attestation as a reliable source is being decided in agency rulemaking this fall. That decision will determine how many of your patients keep coverage without a paperwork fight.

10 weeks away

Though the CR bought Congress only ten weeks, nothing has changed for health centers. Next year's federal funding decisions will be made between November 4 and December 31 by people who will be hearing from every sector at once. Organizations that arrive in that window with a number, a district, and a specific request will be heard, while those that arrive with a general appeal for support will be told the package is already written.