DOH Releases 1115 Medicaid Waiver Request and Solicits Comments
The Department of Health (DOH) has released its proposed 1115 Medicaid waiver amendment request, seeking $13.5 billion over five years to address health disparities and "systemic health care delivery issues." The waiver request, entitled "Strategic Health Equity Reform Payment Arrangements: Making Targeted, Evidence-Based Investment to Address the Health Disparities Exacerbated by the COVID-19 Pandemic," seeks to improve the health and health equity among Medicaid beneficiaries by addressing social care needs and leveraging advanced value-based payment (VBP) arrangements to do so. The waiver request must be approved by the Centers for Medicare and Medicaid Services (CMS) before it can be implemented. It is open for public comment until May 13, 2022. There will be two virtual public hearings on the waiver request, on April 28th and May 3rd (see registration information below).
The proposed waiver is focused on achieving four principal goals:
- Building a more resilient, flexible, and integrated delivery system that reduces health disparities, promotes health equity, and supports the delivery of social care;
- Developing and strengthening supportive housing services and alternatives for the homeless and long-term institutional populations;
- Redesigning and strengthening system capabilities to improve quality, advance health equity, and address workforce shortages; and
- Creating statewide digital health and telehealth infrastructure.
To advance these goals, the waiver will support the development of two new types of entities, Health Equity Regional Organizations (HEROs) and Social Determinants of Health Networks (SDHNs), to identify social care needs and organize the delivery and financing of interventions to support them. Both entities will promote the integration of social care and health care into the state's Medicaid program to increase health equity.
HEROs will be mission-based organizations that build a coalition of managed care plans; local health departments; hospitals and health systems; community-based providers; providers of long-term services and supports (LTSS), including those who serve individuals with intellectual/developmental (I/DD) or physical disabilities; community-based organizations (CBOs) organized through SDHNs (as described below); Qualified Entities (QEs); consumer representatives; and other stakeholders. Only one HERO will be authorized in each of nine regions based on the nine regions used by DOH for Medicaid managed care rate setting. The HEROs would receive limited planning grants; receive data from national, State, local, and proprietary data sources; and "assume a regional planning focus in order to create collaborations, draw insights from different data sources and needs, and develop a range of VBP models or other targeted interventions suitable for the populations and needs of each region."
SDHNs would be networks of CBOs in each of the nine regions that would function as independent practice associations (IPAs) organizing the delivery of social services and VBP arrangements to support them. Funding for the SDHNs will total $116 million per year, with each region receiving $12 million per year ($15 million for New York City). The cost of the SDHN per region includes the initial infrastructure, staffing, coordination of CBOs, capacity building of CBOs, and contracting.
In addition to these two major initiatives, the waiver request includes, among other proposals:
- Supportive Housing: New York requests $1.57 billion over five years to fund the supportive housing initiatives described above, including community transitional services, tenancy supports, and medical respite programs;
- COVID-19 Unwind Quality Restoration Pool for Financially Distressed Hospitals and Nursing Homes: The waiver includes $1.5 billion for facilities that have a high Medicaid payor mix to engage in VBP arrangements and facilitate quality improvement and advancement of health equity.
- Workforce Development: The State requests a reinvestment in Workforce Investment Organizations (WIOs) to focus on the needs of their respective regions and coordinate with the other WIOs to facilitate a cohesive approach to workforce development and share best practices. The charge of the WIOs would be expanded to include a wider range of training, recruitment, and retention initiatives that would address the workforce shortage crisis across the care continuum, facilitate implementation of the health equity work of this waiver, and create opportunities for career advancement.
- Telehealth: The waiver would create an Equitable Virtual Care Access Fund and invest $300 million in telehealth initiatives, including several projects focused on long term care.
LeadingAge NY is analyzing the proposed waiver and will be submitting comments. It has submitted several sets of comments on the previously released waiver concept paper and has testified before the Public Health and Health Planning Council about it (LeadingAge NY comments on the concept paper are available here and here). Although we see improvements in the latest version of the waiver, we are concerned that the framework described in the waiver request does not adequately take into account the needs of older adults, the social care services already covered by Managed Long Term Care (MLTC) plans, and the fragmentation of funding and services between Medicare and Medicaid. Significantly, the waiver's reliance on advanced VBP arrangements (e.g., global capitation) as the principal source of new funding for providers may result in little investment in the long term care system due to the Medicare/Medicaid divide and federal constraints. We encourage members to share with us their feedback on the waiver for inclusion in our comments.
Registration for the April 28th virtual hearing is available here, and registration for the May 3rd hearing is here. Both hearings will be held from 1 to 4 p.m. Individuals wishing to speak must insert the letters "SP" before their name in the online registration form. Comments may be submitted here. More information is available here.
Contact: Karen Lipson, email@example.com, 518-867-8838