Providing Elective Abortions as an “Other Line of Business”

Providing Elective Abortions as an “Other Line of Business” in Accordance with Federal Law: Navigating Cost Allocation Principles and Federal Interest
Thursday, February 16th, 2023
TIME:  10:00am-12:30pm

Historically, federally funded FQHCs have not been a major abortion provider given that federal law prohibits using Department and Health and Human Services (HHS) grants (including Health Resources and Services Administration (HRSA) Health Center Project grants) to provide elective abortions. It is feasible, however, for federally-funded FQHCs to provide elective abortions in compliance with federal law if those services are financially segregated from the Health Center Project. In October, the Department of Health Care Services (DHCS) provided a billing pathway for FQHCs to bill for abortion services through fee-for-service Medi-Cal, thereby creating a means for Medi-Cal reimbursement outside of an FQHC’s PPS rate. This guidance was strictly related to billing and did not address compliance considerations associated with segregating elective abortions from the Health Center Project. To provide additional guidance, CPCA is partnering with Feldesman Tucker Leifer Fidell and Dr. Panna Lossy to host a training session on providing abortion services in a compliant manner. 

Expert attorneys, Ted Waters and Carrie Riley will review the applicable federal law restricting the delivery of elective abortions within a federally funded Health Center Project, with a focus on the legal and accounting principles associated with providing elective abortions as an “other line of business.”  The presenters will address considerations related to cost allocation, federal interest, and program income. Dr. Panna Lossy will be joining us to give a clinical perspective and discuss best practices when providing therapeutic abortions at health centers.


  • Discuss the Abortion Care in FQHCs, Hyde Amendment, and Section 330 Grants.
  • Describe the key legal and accounting considerations applicable to establishing elective abortion as an “other line of business.”
  • Understand and identify common compliance errors associated with cost allocation and federal interest.
  • Discuss best practices and provide a clinical perspective on providing abortion services.


  • Ted Waters, Attorney, Feldesman Tucker
  • Carrie Riley, Attorney, Feldesman Tucker
  • Panna Lossy, MD, Faculty Santa Rosa Family Medicine Residency, TEACH faculty

Payment is due at time of registration.

  • CPCA Member: $100
  • Non Member Health Center: $100
  • Associates: $112.50
  • Non Member, Non Health Center: $125

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Disclaimer:The information on this session is intended only to provide a general overview of the topics addressed.  This session is not intended to provide legal advice or substitute for the guidance, counsel or advice of legal counsel on any matters particular to a specific primary care clinic. CPCA does not endorse companies or products. Advertising and sponsorship revenue supports our not-for-profit mission. 

2/16/2023 10:00 AM - 12:30 PM
Online Via Zoom Meeing

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