FABA Legislative and Public Policy Committee

Eric Prutsman – Lobbyist & Legal Counsel – Email Eric

Steve Coleman – Public Policy Director – Email Steve

Yulema Cruz – Co-Chair – Email Yulema

Mary Riordan, PhD – Co-Chair – Email Mary

Political Action Committee Email - Email the Committee


Legislative Update – Post-2020 Session – HB 731, Agency for Health Care Administration

Governor DeSantis did sign HB 731 – Agency for Health Care Administration on June 30, 2020, that contains an exemption from the health care clinic licensure for Medicaid providers. Now that the exemption is law, it is our understanding, after speaking with the Medicaid Policy Office at AHCA that the exemption will be automatic for behavior analysts enrolled as Medicaid providers and no further action will be needed to be taken by Medicaid providers. We also expect the Agency to announce that the December 1, 2020, health care clinic licensure requirement deadline for behavior analysis groups will be repealed from the Medicaid Enrollment Handbook and that administrative rulemaking will be necessary to effectuate the change. We are anticipating a Provider Alert soon from AHCA on this matter. Please stay tuned and attend the September  17, 2020, panel discussion with AHCA, APD, and CASP at 4pm during the 2020 FABA Conference for further information.





Legislative Update – Updates to Health Care Clinic Licensure for Florida Medicaid Providers - OCTOBER 5, 2020

During the 2020 Florida legislative session, an exemption to health care clinic licensure for Florida Medicaid providers was added to Section 400.9905, Florida Statutes. As a result of this legislative change, Florida Medicaid providers are not required to seek health care clinic licensure.  

Effective July 1, 2020, Florida Medicaid does not require any provider to show proof of licensure as a health care clinic nor proof of exemption from licensure as a health care clinic. Current, reenrolling, or new Florida Medicaid providers do not need to show proof of licensure as a health care clinic nor proof of exemption from licensure as a health care clinic.

Florida Medicaid is working to update the Enrollment Policy (Appendix E) to remove these requirements to align with Section 400.9905, Florida Statutes for all of the below providers: 

Provider Type Code

Provider Type Description


Advanced Practice Registered Nurse (Groups only)


Audiologist (Groups only)


Behavior Analysis (Groups only)


Chiropractor (Groups only)


Community Behavioral Health Services


Dentist (Groups only)


Hearing Aid Specialist (Groups only)


Independent Laboratory


Licensed Midwife (Groups only)


Optician (Groups only)


Optometrist (Groups only)


Physician (Doctor of Medicine - M.D.) (Groups only)


Physician (Doctor of Osteopathic Medicine D.O.) (Groups only)


Physician Assistant (Groups only)


Podiatrist (Groups only)


Portable X-ray Company


Registered Nurse/Registered Nurse First Assistant (RNFA) (Groups only)


Rural Health Clinic (RHC)


Specialized Therapeutic Services (Groups only)


Therapist Physical Therapy, Occupational Therapy, Speech Therapy, and Respiratory Therapy (Groups only)

Florida Medicaid providers may voluntarily apply for a certificate of exemption from licensure as a health care clinic. Most health care providers who apply for an exemption certificate do so because Medicare or private insurance companies require documentation of licensure or exemption from licensure prior to authorizing reimbursement for services. If you choose to apply, application forms and information are online at http://ahca.myflorida.com/MCHQ/Health_Facility_Regulation/Hospital_Outpatient/HealthCareClinic/hcc_exemption.shtmlPlease note: The health care clinic rules and application forms have not yet been updated to reflect the recent statutory changes. If an entity is attempting to qualify under a newly added exemption, they can submit an application along with appropriate fees, a cover letter stating the exemption sought and appropriate supporting documentation.

For additional assistance please contact the Florida Medicaid Helpline at 1-877-254-1055.