We applaud
the Governor and NYS Department of Health for developing an MRT waiver framework
that recognizes the importance of primary care.
Today, 2.4 million New York State
residents lack access to primary care, while
New York ranks highest in the nation in avoidable hospital use
and cost, and sixth in the nation in total health care spending.
A community-based
health care infrastructure with sufficient primary care at its center is
critical to building and sustaining the high-performing, integrated systems of
care that will achieve the Triple Aim of better health, better care, and lower
costs. True integration will challenge
the “silos” that have traditionally defined New York’s health care environment,
and create more meaningful collaborations among payers, providers and
patients.
To achieve
this, sufficient MRT Waiver funds must be invested to build and sustain
patient-centered, community-based primary and preventive care, family planning, behavioral
health and support services capable of managing and coordinating care in
communities of need.
Note: recommendations below “track” the subject areas in the MRT Waiver Framework
Invest in Primary Care Expansion
Create
a revolving capital fund for community-based care investment.
Such a fund would leverage private sector investment and provide a permanent
source of affordable public/private financing for community-based care
providers.
Maintain
and expand Patient Centered Medical Homes (PCMH).
New York State’s Medicaid PCMH incentive pool has resulted in the highest
number of PCMH providers and practices in the country. The State should ensure
that the incentive payments are sufficient to ensure the sustainability of
existing PCMHs and encourage additional providers to adopt the PCMH model.
Additionally, New York State should allocate funds to community based providers
and stakeholder collaborations for technical assistance to facilitate a PCMH
implementation as well as support activities to sustain and spread the models
beyond the initial implementation period.
Support New Care Models including Health Homes
Support
technical assistance for providers to develop/integrate into new care models. New systems of care like health homes and
accountable care organizations require a high degree of technical knowledge
(e.g., legal issues related to anti-trust regulations, risk-sharing payment
models, severity adjustments, provider attribution, HIT and HIE, performance
measurement, patient risk stratification, and many more). The State should
establish a mechanism to guide stakeholders in addressing these issues and a
pool of funds that supports assistance related to these technical issues,
including funding collaborative efforts where different initiatives work
together to resolve the issues.
Support
the co-location of primary care services with behavioral health services. Address the State and federal regulatory
barriers to these arrangements and provide the capital and operational funding
to support their development.
Support
telemedicine expansion and sustainability. Support
investments in and payment for telemedicine and address other regulatory hurdles
to expand and sustain its use.
Support
the Health IT needs of integrated systems of care.
Integrated systems of care such as Health Homes need affordable software that
allows all participating organizations to share a patient care plan across care
settings. This software must be interoperable with EHRs and New York State’s
SHIN-NY infrastructure.
Expand the Vital Access Provider Program and Safety Net
Provider Program
Increase
funding for the primary care safety net system.
Although there have been some increases in primary care dollars for the
uninsured through the Indigent Care Pool, the funding still does not keep pace
with the demands for services for the uninsured in primary care settings. Sufficient funding will enable new systems of
care to sustainably incorporate uninsured residents.
Support Hospital Transition
Preserve services that are at risk from
hospital closures and restructuring. Monitor the availability of primary
care capacity and exercise authority when such capacity is at risk from
hospital consolidations, mergers, restructuring, and closings. Resources should
be deployed not only to hospitals but also to community health centers and
other community-based providers that will be playing a role in absorbing and
strengthening capacity.
Support
the sustainability of existing capacity and incentivize the expansion of
community-based care. Ensure that community-based providers
are paid appropriately to sustain the full range of services they provide. This
includes, for example, school-based health centers that offer integrated
services such as primary care, dental, and mental health services. Methods
should also be developed to encourage expansion of community based care,
including capital grants, provider incentive payments, regulatory relief, and
technical assistance support.
Support
the co-location of primary care services in emergency departments.
Address the state and federal regulatory barriers to these arrangements and
provide the capital and operational funding to support their development.
Support Medicaid Supportive Housing Expansion
Support
the co-location and integration of high quality primary care with supportive
housing. Provide the capital and operational funding to support
these developments.
Support Workforce Training
Develop
and expand methods for increasing the workforce for community-based care,
such as
- enhanced Medicaid PMPM rates to recruit
and retain primary care providers in underserved areas;
- significant investment in Doctors
Across NY and the Primary Care Service Corps
- development of programs that recruit,
train, and retrain health care workers who will be vital to the integrated
systems of care, including care coordinators, case managers, and community
health workers; and
- demonstrations that enhance scopes of
practice.
Invest in Regional Health Planning
Develop
a health planning infrastructure. Enhance its support of regional health
planning initiatives and infrastructures as well as collaborations that support
combined regional and state-level planning efforts.
Ensure
access to data on the total cost of care. Having access
to claims data for all payers will be critical to targeting improvements that
will reduce costs. In addition to continuing to develop the Medicaid Data
Warehouse and the all-payer claims database, the State should also work with
CHCANYS to incorporate claims and other cost-related data into the CHCANYS
Center for Primary Care Informatics’ (CPCI) statewide data warehouse to improve
the analytic capacity of community-based providers.
Support
training and technical assistance on the use of data to improve quality and
monitor performance. The development of data analysis
skills is becoming increasingly critical as providers assume greater
accountability for patient care, outcomes, and cost. The State should provide a
pool of funds to support training and technical assistance for these
activities.
Developed by the Community Health Care Association of NYS and the Primary Care Development Corporation
