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DOH Convenes Public Hearings on Draft Medicaid Waiver

The Department of Health (DOH) convened two virtual public hearings to receive comments on its draft 1115 Medicaid waiver amendment request, seeking $13.5 billion over five years to address health disparities and "systemic health care delivery issues." Dozens of stakeholders offered comments reflecting a broad range of priorities and concerns. LeadingAge NY criticized the proposed waiver's lack of attention to the needs of older adults and its lack of meaningful investment in the long term care system. We pointed out that although the draft waiver is intended to promote health equity, it perpetuates inequities in the delivery of health care and investment in services for older adults.

Specifically, the draft waiver's reliance on advanced value-based payment (VBP) arrangements to drive investment ignores the bifurcation of financing and benefits between Medicare and Medicaid for older adults. As a result, the proposed waiver is unlikely to drive any meaningful investment into the long term care system during the term of this waiver.

LeadingAge NY's comments supported the waiver's goal of integrating interventions addressing the social determinants of health into the delivery of health care. However, we noted that a broad array of social care interventions is already embedded in New York's Managed Long Term Care (MLTC) and Program of All-Inclusive Care for the Elderly (PACE) programs, in the services offered by long term care providers, and in the non-medical aging services system. We recommended that the waiver avoid duplicating those efforts, creating new layers of costly administration, or forcing providers and plans to reconfigure services and disrupt existing relationships. LeadingAge NY also pointed out that the proposed waiver’s approach to social care assessments is preferable to, and inconsistent with, DOH’s current policy of implementing independent assessment for personal care and MLTC. We recommended several modifications to the draft waiver, including the use of an alternative, targeted mechanism for investment in the long term care system through the waiver – in lieu of generic investments through advanced VBP arrangements that will never reach long term care.

Recordings of the hearings and the slides presented by DOH will be posted here. More information about the waiver was previously reported here.

Contact: Karen Lipson, klipson@leadingageny.org, 518-867-8838