2012 – 2013 PRIORITIES
-MRT PHASE 2 IMPLEMENTATION FOR BEHAVIORAL HEALTH (FIREWALL BEH HEALTH RESOURCES)
– HEALTH INSURANCE EXCHANGE, ESSENTIAL HEALTH BENEFITS AND ACCESS TO CARE FOR NEW YORKERS IN NEED
- NYS 1115 WAIVER SUBMISSION AND COMMUNITY REINVESTMENT
- EXEMPTION OF BEH HEALTH WORKFORCE FROM COMPLIANCE WITH SOCIAL WORK LICENSING LAW
- IMPLEMENTATION OF BI-DIRECTIONAL INTEGRATED CARE, COLLABORATIVE CARE MODEL
September 28, 2012
Donna Frescatore, Executive Director
NYS Health Benefits Exchange
Dear Ms. Frescatore:
On behalf of the Board of Directors and members of the NYS Council for Community Behavioral Healthcare (“The Council”), I would like to thank you and your colleagues for this opportunity to share our comments regarding your proposal to define how performance and satisfaction ratings are displayed for Qualified Health Plans (QHP’s) available in the Exchange beginning in 2014.
Members of the NYS Council have a strong appreciation for the tight timeframes associated with implementation of the NYS Health Insurance Exchange (2014). We understand that many significant milestones must be achieved along the way to full certification of the Exchange. And so while we appreciate the proposed interim strategy to rely on prior reporting techniques that utilize existing measures for performance and satisfaction for Qualified Health Plans operating in the Exchange between 2014-2016, we urge you not to wait to change the way in which we measure performance of and satisfaction with plans that provide behavioral health (mental health and substance abuse/chemical dependence) services now or once the Exchange is implemented.
As we heard during the September 2012 NYS Health Insurance Exchange stakeholder meeting, all of the decisions being made now regarding the operation of the NYS Health Benefits Exchange in the future will have a direct impact on each and every New Yorker who will receive health insurance benefits through a Qualified Health Plan (QHP) inside and outside the Exchange beginning in 2014.
For this reason and because our members have significant prior experience and expertise dealing with the consequences associated with mental health and substance abuse consumers who are not always able to use their health insurance benefits, we feel that during the interim period (2014-2016) New York State must re-double its efforts to conduct adequate surveillance of and compile accurate and timely information about the performance of health plans participating in the Exchange, and to communicate this information in a manner that makes sense to individuals with cognitive and other challenges.
The first step towards achieving this goal is to make sure we have robust measures of plan performance inside and outside the Exchange.
It is critical for New York to take a hard look now at: 1) the resources the state currently devotes to the collection of performance information including but not limited to compliance with state contracts; 2) the reporting mechanisms in place to gather performance data from participating health plans and customers; and, 3) how we currently meet the needs of health insurance consumers in terms of spreading the word regarding their rights and responsibilities as beneficiaries – especially in areas including access to care and coordination of behavioral health benefits.
Criteria for Measuring Plan Performance
Current attempts by the state to monitor behavioral health plan behavior and outcomes (Surveillance), to require plans to reach out to their insured in local communities and engage at-risk clients to seek early detection and intervention services (Service Penetration), to ensure continuity of care so clients get the right amount of care at the right time (Service Intensity), to assure Network Adequacy, and to forbid plans from operationalizing Medical Necessity in such a way as to dilute the gains made as result of federal and state parity – could be and must be better. We do not feel that change should be put off to 2016
With this in mind, we are pleased to share our recommendations regarding the measures we think NYS should utilize to evaluate health plan and behavioral health plan performance inside and outside of the Exchange. We think these broad categories will help regulators to identify measurable objectives to be associated with each category. The extent to which the Qualified Health Plans achieve each objective should be clearly communicated to Exchange consumers in a manner that is culturally sensitive and that accommodates the unique needs of the impacted population utilizing the information.
Our criteria fall into the following high priority categories. We offer some brief comments alongside our suggested criteria – to expand on our primary concern:
Area 1: Enrollment and Member Services (a/k/a Outreach and Enrollment)
Comment: Measurable objectives including the extent to which the Plan reaches out to consumers and is successful in engaging him/her for early treatment services; ease of enrollment; availability of customer care services to guide special needs clients through the process of enrollment; special efforts taken by the Plans to reach disabled individuals with cognitive and/or other impairments.
Area 2: Network Capacity and Accessibility
(Other terms to describe this category include: Provider Network Characteristics and Accessibility to Health Care Services)
Comment: Does the Plan have adequate numbers and breadth of providers in its’ Network to guarantee efficient and effective care to all covered lives? If we think so, how do we KNOW this is true in the domain of behavioral health services? Does the State conduct adequate surveillance around Network Adequacy for ALL health insurance services including behavioral health services? What happens to those plans that do not meet current contract standards? There are rewards for meeting contract terms but are there disincentives for not meeting them? We strongly suggest the addition of “Any Willing Provider” language to the contracts that will be executed between the State and Qualified Health Plans in and out of the Exchange. Market forces can determine which providers are most regularly utilized by the Plans. Current waiting lists for behavioral health services across the state dictate robust provider networks.
Area 3: Benefit Management (Including Member Materials, Medical Necessity Determinations)
Comment: Although sometimes contract language addresses investigational services, utilization management, prior authorization, and review procedures, typically there is NO contract language stating that while scientific evidence should be a priority if it is not available for people with specific disabilities and the services they need, then professional standards or consensus opinion MUST be considered in all Medical Necessity determinations
Area 4: Care Management
(Operationalized here in New York as a continuum of activities including Care Coordination and Case Management)
Comment: This is the extent to which the Plan works to coordinate and “de-fragment” care provided to an insured that may be receiving services inside and outside stated Plan benefits.
Area 5: Quality Improvement
Area 6: Performance Measurement
While we know New York State cannot change every aspect of the way the current health insurance delivery system operates immediately, we think there is time to make changes in terms of the expectations we have of Health Plans now and in the future under the Exchange.
Over the past 5 years, the NYS Council has discussed with state officials our ongoing concerns that the measures of performance currently built into behavioral health service plan contracts serving New Yorkers – not just those with MMC or Medicaid FFS benefits are inadequate. We have learned that surveillance activities designed to monitor plan behavior and collection of outcomes is often focused on medical (physical health) care, but that the state does not appear to have adequate resources to monitor network adequacy and other access to care criteria in the behavioral health arena. Gains made in the implementation of parity here in NYS are often mitigated by plan determinations that are not guided by contractual language that forbids them from falling back on excuses for denial of coverage. This is why we say it is not enough to defer this conversation and fall back on existing measures of plan performance until 2016.
We are pleased to be able to share our thoughts regarding your decision to utilize existing performance measures; however, we think there is a discussion to be had now and interim steps we can take during the period leading up to Exchange implementation, and then again between 2014-2016.
If surveillance is not increased and indicators of performance are not improved, we fear behavioral healthcare clients at all levels of service acuity will not get the right amount of services when they are needed by the client. It is with this concern in mind that we respectfully urge a fuller discussion regarding our current and future expectations of QHPs in the early years of the NYS Health Insurance Exchange.
The NYS Council would be honored to assist you to convene a group of behavioral health leaders from across New York, to include consumers and family members, who can speak to the issues we have raised in our comments. We stand ready to assist you at anytime and we thank you for this opportunity to communicate our concerns.
Most respectfully submitted,
Lauri Cole, MSW, Executive Director
NYS Council for Community Behavioral Healthcare
New York State Council
Community Behavioral Healthcare
August 15, 2012
Ms. Danielle Holahan
New York State Health Benefit Exchange
New York State Department of Health
The New York State Council for Community Behavioral Healthcare is pleased to submit our comments on New York’s selection of an Essential Health Benefits (EHB) benchmark plan for use in the individual and small group insurance markets.
The New York State Council for Community Behavioral Healthcare (“The Council”) is a statewide membership association composed of 95 community-based organizations that provide life-sustaining mental health and substance use treatment and recovery services to New Yorkers in settings including hospitals, county-operated programs, and freestanding non-profit agencies.
Members of the NYS Council commend the Cuomo Administration for having the foresight to focus significant state resources on the establishment of a NYS-operated Health Benefits Exchange long before most other States. Over the last two years, we have benefitted from your invitations to attend all Administration-hosted stakeholder meetings on topics including Health Reform, the Health Benefits Exchange and most recently, Essential Health Benefits. We have tried to keep our healthcare advocacy partners across the state informed regarding the implications of the policy decisions facing New York State and the Administration as it moves to implement the Exchange. Policy decisions regarding essential benefits will have a real and significant impact on nearly every New Yorker, and especially those living with challenges associated with addictions and mental health disorders. We truly appreciate all of your efforts to make information available to stakeholders as the process moves forward.
Decisions about health benefits must recognize that 83 cents of every dollar is spent on chronic health conditions. Significant among these are mental health illness and addiction, either as a primary disorder such as depression or anxiety, or co-occurring with diabetes, heart disease, or another chronic condition.
Community expectations about mental health and addictions treatment have evolved over the years. While stigma remains a barrier, new norms anticipate that these disorders will be regarded like any other disease, reflecting the reality that treatment works and recovery is possible.
When providers have available the right set of tools, they will save money in the long run; healthy people cost society much less than sick people who are not receiving the right treatment at the right time. Federal and State law recognizes that mental health and substance abuse treatment services are equally as important as coverage for any other health condition. New York State sets the standard when it comes to our collective commitment to treat these diseases as critical components of good healthcare.
Having health insurance (regardless of the type) and being able to use it as needed are two different things. Too many New Yorkers with addiction and mental health challenges still experience serious difficulties accessing and utilizing their health insurance benefits. Potential care recipients get caught in the maze associated with finding a doctor who will take their insurance. Clinicians/providers often give up and close their practices to certain new clients when they have had enough of the frustrations associated with prior authorization and varying definitions for medical necessity. Treatment on demand means clients can get the help they need when they need it. This requires far better surveillance of contracts and day-to-day practices of health insurance plans, and the providers within networks. It is imperative for New York State to take the reins and adequately monitor Qualified Health Plans and their behaviors within and outside the Exchange.
As New York moves forward with implementation of the NYS Health Benefits Exchange, we urge the Administration to remember that mental health and substance use illnesses have benefitted from increasingly sophisticated treatment practices based on scientific research supporting medication assisted options, cognitive behavioral therapies and an evidence based patient placement criteria. The benefit package should entail full coverage of all medically necessary services across the continuum of care in both mental health and substance abuse treatment.
Medical necessity must be defined to support parity and enforce oversight of the benchmark options.
The foundation of comprehensive coverage requires that a diagnosis by a qualified healthcare professional be the starting point to receive appropriate treatment. This clinical, medical and practical decision tree is as rooted in nationally accepted criteria as DSM 5 and Medicare criteria for medical illnesses. Therefore precertification limits and other “caps” to treatment should not be imposed on mental health and substance abuse treatment options that are not placed on other medical conditions.
Our comments reflect our understanding of the HHS guidance to states regarding the identification of a benchmark plan. We know HHS guidance largely prohibits states from changing the basic plan design of any of the 10 plans under consideration here in New York. It is our understanding the only time states can change plan design is in order to bring a potential benchmark plan up to the standards set forth in the ACA regarding essential health benefits.
Having said this, we remain concerned that some of the core programs and services that we believe and research shows should be included as essential mental health and substance abuse benefits here in New York will not be included due to a variety of factors including HHS guidance regarding implications of adding new state mandates. As such, we argue for these services in our formal comments to the Administration pertaining to the use of reinvestment dollars associated with approval of New York’s 1115 waiver amendment.
Below is a series of statements that summarize our thoughts regarding the principles the Administration should follow as it works to identify a benchmark plan and define essential health benefits for all New Yorkers including individuals with significant mental health and addiction challenges:
- Adequate and accessible treatment of mental illness, emotional disturbance and addictions is essential to achieving the triple aim goals of health reform—better care, better results and lower costs for the population.
- Early identification and voluntary recognition and treatment result in fewer social consequences, better prognoses, and less secondary co-occurring illness and complications.
- Mental illness and addiction are complex and chronic conditions that can affect the mind, body and overall daily functioning.
- Efforts to too narrowly define covered benefits shift the risk, cost and consequences to the covered person and to others such as workers comp, jails, corrections, disability, or government programs such as Medicaid.
- In the context of health reform—with changes to underwriting, dollar limits on coverage, loss ratios, an emphasis on “total cost of care” and requirements for mental health and chemical dependency parity—a continuum of mental health and addictions services is an essential tool to appropriately manage care for a population.
- New York’s choice should allow an easy transition for consumers moving to the Exchange as well as those that qualify for services through the Exchange at the point of initial implementation. New York must do everything in its power to inform and assist New Yorkers – and particularly those with special needs regarding their choices, so as to guarantee access to high quality care and continuity of care.
Given the considerations (listed above) we believe the Empire Plan provides the most comprehensive coverage for New Yorkers, and especially those requiring treatment for chronic conditions including but not limited to addictions and/or mental health disorders.
We agree with the United Hospital Fund’s report analyzing the benchmark options. The Report highlights the value of the Empire Plan for its ability to minimize significant state defrayal costs and to serve as a bridge during the transition period when NY implements the Exchange.
It is important to note that the Empire Plan was used as the backstop during the crafting of Timothy’s Law legislation.
The Empire Plan is the only benchmark that meets or exceeds almost all of New York’s individual and small group benefit mandates.
The Empire Plan offers stability and a high level of certainty in addition to its comprehensiveness, due to its large size and clearly identifiable benefits.
At a recent Administration-hosted stakeholder meeting representatives from Milliman reviewed some of their analysis regarding the ten most popular plans in New York. The Report noted the Empire Plan had a slightly higher predicted effect on premium cost. According to Milliman, utilizing the Empire Plan as the benchmark for Essential Health Benefits would result in marginally larger increases in medical costs for insurance when compared to the largest commercial small group products (a difference of 3.2 percent from the lowest priced Oxford small group plan and 1.2 percent over the Federal Employee Health Benefit Plan). While affordability of coverage is extremely important, we believe the marginally higher price of the Empire Plan will be significantly offset by the significant changes in the marketplace achieved by the full implementation of the Affordable Care Act (ACA).
A note about the Milliman exhibits: While the spreadsheets provided show the existing benefits offered by the various plans under consideration, they do not show which of these benefits must be supplemented to meet federal parity requirements. For example, we were unable to ascertain whether federal mandates for mental health parity were included in treatment visit limits.
New Yorkers need to have a serious discussion regarding the need for increased access to a variety of mental health and addiction treatment programs and services that we know will save money for the state and improve outcomes for behavioral healthcare recipients once they are standardized across the continuum of care. We would like to meet with Exchange staff to discuss the requirements New York will expect of QHPs in the Exchange.
We know the Administration awaits further guidance from HHS on a number of critical issues. HHS seeks to define certain core concepts that may/may not work in our favor. We look forward to a dialogue with you regarding forthcoming HHS guidance. Thanks again for this opportunity to comment on this critical decision facing New York at this time.
Lauri Cole, LMSW, Executive Director
New York State Council for Community Behavioral Healthcare
911 Central Avenue, #152
Albany, NY 12206-1350
Below is a copy of the letter NYS sent to CMS earlier today communicating our choice for an Essential Health Benefits Plan AND discussing NYS supplemental coverage choices.
Gustavo Seinos, Project Officer
Center for Consumer Information and Insurance Oversight Centers for Medicare & Medicaid Services
200 Independence Avenue SW
Washington, DC 20201
This letter is intended to formally notify you of our selection of a benchmark plan that meets the Essential Health Benefits requirement as outlined in the Affordable Care Act (ACA). New York State has selected the largest small group plan in the state, Oxford EPO, as the benchmark plan. According to an in-depth analysis by Milliman for New York, this plan provides comprehensive benefit coverage to consumers while minimizing costs to both the individual and small group markets.
The state has electronically submitted our benchmark plan selection to the Health Insurance Oversight System on Monday, October 1, 2012.
In addition to the selection of a benchmark plan, per HHS guidance, we have indicated the coverage areas in which benefits will be supplemented in order to meet ACA requirements. We have outlined these areas and the preferred supplementation method below:
Pediatric Dental/Vision Coverage – New York State prefers to supplement the benchmark selection with the current pediatric dental/vision benefits that are offered as part of the state’s CHIP coverage.
Habilitative Services – New York State prefers that coverage parameters for habilitative services be offered on parity with rehabilitative services.
Mental Health/Substance Abuse Parity - Any existing limits on these benefits must be removed as mental health parity is included as part of the EHB definition.
Removal of Annual/Lifetime Dollar Limits - New York State awaits further federal guidance on the process for substituting dollar limits on benefits with actuarially equivalent quantitative limits (e.g., annual visit limits).
October 1, 2012
We understand HHS intends to release state-specific benchmark plan selections as part of a federal Notice of Proposed Rulemaking (NPRM) that will be open to public comment. We look forward to continuing to work with you throughout this process and welcome further federal guidance on this important issue.
New York State Health Benefit Exchange
ESSENTIAL HEALTH BENEFITS AND NYS HEALTHCARE REFORM
State leaders are engaged in a process to identify a “benchmark plan” that all other insurance plans participating inside the NYS Health Insurance Exchange would need to emulate. The identification of Essential Health Benefits in 10 core areas (as required by HHS) is a critical issue for our mental health and addiction treatment providers and the individuals we serve! Representatives from the NYS Council continue to attend meetings and weigh in with the Administration on behalf of mental health and addiction treatment providers. Invitation only meetings, hosted by the Administration and by various policy and research organizations around the state continue to provide us a window into the decision- making process. Our attendance at these meetings permits us a unique opportunity to weigh in to protect access to a broad range of services currently available to New Yorkers in need of mental health and/or addictions treatment services.
On May 18, we co-hosted a meeting that brought together mental health and addiction treatment advocates to bring everyone up-to-date on the health reform here in NYS, and the Essential Health Benefits discussion.
Read more about Essential Health Benefits and Health Reform here:
(Letter to NYS Council members, 5/23/2012)
Last week the NYS Council co-hosted a meeting for statewide and regional advocates to understand the work being completed by NYS to identify a benchmark plan that all insurance carriers participating in the NYS-run Health Insurance Exchange must emulate in terms of the benefits offered in 10 core areas of Essential Health Benefits listed in the Affordable Care Act. The Cuomo Administration will soon release a study performed by Milliman (the largest consulting and actuarial firm in the world) and commissioned by NYS that takes a deep dive into the 10 most subscribed relevant plans here in NYS to ascertain what benefits are available in each, their actuarial values, how they conform with the requirements laid out by HHS, etc. It is very likely Milliman will make a recommendation to NYS regarding which plan should be considered for identification as our “benchmark plan”. Bear in mind that this impacts not only the small and mid-size commercial insurance market but also the Medicaid expansion benefit here in NY.
For advocates, the business of analyzing the most subscribed plans here in NYS in order to understand the comprehensiveness of mental health and substance use benefits within these plans is a bear. Fortunately, NYS is required to follow Timothy’s Law that brings real protections for those we serve built into the EHB discussion. But the choice NYS ultimately makes regarding which plan will serve as the benchmark will have significant consequences for all New Yorkers and so the NYS Council continues to follow the discussion closely, weigh in with Administration officials, and convene our partners in an effort to keep us all on the same page, while also sending a clear message to decision-makers.
The group convened last Friday had the benefit of discussion with Troy Oeschner from the Department of Financial Services and our colleagues from the National Council. We are grateful to them for their time and the wealth of knowledge they possess on these complicated issues. Advocates across New York are now on better footing with regards to implications for our community and we will be continuing to work together. We will keep you posted.
“Essential Health Benefits: What Does the New HHS Guidance Mean for Behavioral Health <http://mentalhealthcarereform.org/essential-health-benefits-what-does-the-new-hhs-guidance-mean-for-behavioral-health/>
· Blog post by NACHC on EHB and Medicaid benchmark <http://blogs.nachc.com/policyshop/?p=392>
PRIORITY: NYS WAIVER SUBMISSION TO CMS AND REINVESTMENT IN COMMUNITY BEHAVIORAL HEALTH PROGRAMS AND CARE RECIPIENTS
NEW YORK STATE COUNCIL FOR COMMUNITY BEHAVIORAL HEALTHCARE
COMMENTS REGARDING DOH DRAFT 1115 WAIVER PROPOSAL
July 20, 2012
We appreciate the opportunity to provide comments on the Department’s draft proposal for an 1115 waiver to reinvest $10b of the savings from various Medicaid Redesign Team initiatives over a five-year period.
Outlined below are some of our thoughts regarding several of the general focus areas in your original draft outline for the waiver.
Please note: These comments are not exhaustive. We look forward to more information becoming available as time goes on and CMS has had an opportunity to consider the NYS waiver outline to be submitted by NYS in August 2012.
We are grateful for the information we have received to date regarding the Departments priorities as well as your efforts to elicit feedback from the public. We look forward to additional opportunities to discuss the waiver with key leaders and decision-makers.
VITAL ACCESS PROVIDER PROPOSAL
The State draft proposes support to “vital access providers” including hospitals, nursing homes, home care, and “clinics.” The Department of Health has not yet indicated whether it intends for behavioral health providers, such as Article 31 (OMH) or Article 32 (OASAS) clinics to be included in this general category, “clinics”. We raised this question during the webinar discussing the VAP proposal however we have not yet received a response to our question.
We urge the State to include behavioral health providers as eligible vital access providers. VAPs will have access to longer-term support that is essential to ensure financial stability and advance ongoing operational changes to improve community care and preserve access to care. This is especially important given the MRT’s Behavioral Health Reform Workgroup recommendation for investment to expand outpatient service capacity.
Like their hospital counterparts, MANY mental health and substance abuse community-based providers are under significant financial pressures. Some are choosing to turn in in their licenses to the state, while others are merging with larger organizations. This situation is likely to result in economies of scale that may be good for the bottom-line, we remain concerned that consolidation could also result just a few large providers in each region of the state. We think this will be detrimental to the preservation of consumer choice.
As counties continue to shed their outpatient clinics and other safety net services (many of which are situated in rural settings where access to care is almost always an issue), the continued viability of core mental health and substance abuse treatment clinics become even more critical to the fabric of the local safety net.
The State should also keep in mind the very fragile financial condition of dedicated children’s behavioral health outpatient clinics where our most vulnerable citizens find the treatment they need thereby avoiding the need for more costly forms of care. These clinics are responsible to clients and their families for a host of services many of which involve cross-systems coordination beyond an occasional collateral contact. These clinics keep kids in school, going to doctor’s appointments and engaged in a structured range of positive mental health treatment and psychosocial activities that preserve community tenure.
As traditional state support is withdrawn, outpatient clinics will increasingly require the same kinds of investment and support as other healthcare providers whose operational costs and reimbursement rates have remained flat or decreased, while capitol funds remain scarce and mandated regulatory compliance activities increase.
As to the question of what criteria should be used to identify Vital Access Providers, we suggest the Department include consideration of network adequacy requirements related to geography and travel times developed for Medicaid Managed Care companies. We know network adequacy problems and unacceptable delays in access to timely care exist in areas across the state for a variety of reasons. Access to care at early stages of a crisis/onset of a disease process result in better outcomes for the patient and lower costs for the state. Therefore, when considering criteria for VAP inclusion, we think the state must give careful consideration to network adequacy and other criteria we typically use to measure access to care.
iNVEST IN NYS HEALTH HOMES
The NYS Council applauds the Department’s continued commitment to find ways to advance care for behavioral health and other Medicaid clients via care management services now available through the NYS Health Home Program. We continue to believe it is critical to make care available to uninsured persons who would not otherwise be eligible for care management services due to their ineligibility for Medicaid (e.g. undocumented immigrants and the uninsured).
The Council urges the use of waiver funds to support Electronic Health Record development and implementation in behavioral health agencies operating as partners in health home networks. To this point, most behavioral health providers and agencies are unable to meet the meaningful use standards for EHR payment enhancements under federal law, while physicians, hospitals, and other Article 28 settings have been benefitting from these incentives for years. While the NYS Council continues to advocate at the federal level for the advancement of legislation to change this situation, these agencies require immediate assistance from the state to develop EHRs and initiate/advance projects dependent on interoperability between primary care and behavioral health service providers. NYS must invest in behavioral health agencies by making funds available that will help level the playing field and make way for the use of best practices and emerging models of integrated care that we know will result in better outcomes for clients.
The Council urges the Department to create a fund to assist providers with capital and temporary operating support funds associated with the establishment and continued operation of Heath Homes. Despite the financial stressors facing many behavioral health providers, most are now required to make significant investments to enhance staffing and re-train workers while increasing compliance and other areas of operations in order to participate in the Health Homes initiative. Investment could come in the form of low or no-interest loans, a matching funds program, or an incentive driven agreement. Network formation, software upgrades and legal costs associated with the formation of new provider structures are just a few of the many expenses facing Health Home leads and their partners. As we know, there is no administrative overhead built into the care management rates to assist providers with these expenses. We believe it is in the state’s best interest to invest in the establishment of several creative financial programs for behavioral health providers that will assist them with these tasks.
EXPAND HOME AND COMMUNITY WAIVER SLOTS FOR KIDS WITH BEHAVIORAL HEALTH CHALLENGES
Home and Community-Based Services (HCBS) waivers allow states to disregard family income for children with severe disabilities who are eligible for institutional placement, but who are cared for at home. The HCBS waivers usually provide an enhanced package of services designed to support families in keeping their children in the community rather than in institutions. However, waiver programs restrict eligibility to a pre-determined number of slots, and can limit enrollment to children with specific diagnoses or disabilities. Only a very small number of waiver recipients and waiver expenditures are linked to HCBS waivers that serve only children.
As New York continues to transform our healthcare service delivery system, every attempt should and must be made to “normalize” the care experience for New York’s kids with behavioral health challenges ad especially for kids with serious emotional disturbances (SED kids). Unmet demand for waiver slots in NYS has resulted in these children receiving fragmented treatment and other services outside of their “natural community”. Residential alternatives are necessary and there will always be children that require out of the home placement; however, waiver slots are also necessary to balance the care system, guarantee options based on the unique needs of the individual and to make more opportunities available for families and caregivers who want to remain intact. We urge New York State to do everything within its’ power to expand the current availability of waiver slots for kids.
INVEST IN PUBLIC HEALTH / BEHAVIORAL HEALTH INNOVATION
With all of the changes occurring at both the federal and state levels, the stars are clearly aligned and the time is now for New York to increase our investment in public health strategies that have shown promise in their ability to decrease mortality associated with serious addiction and/or mental health challenges.
First, we recommend DOH tap into the evidence base of prevention strategies that have been employed in the substance abuse field for some time now. These successful prevention technologies used by OASAS providers can/should be shared with DOH and OMH, and vice versa.
Next, we urge the Department to make significant investments in programs and services that lower incidence of and limit the individuals and societal costs associated with Maternal Depression widely considered a major risk factor for the socio-emotional and cognitive development of children.
Women of childbearing age are particularly at risk for depression, and many of them experience high levels of social morbidity and depressive symptoms that are often unrecognized and untreated. Maternal depression has significant consequences on a child’s development. Untreated maternal depression has been correlated with problems with motor and social skills, success in school, positive adolescent mental health and numerous other factors impacting child development. Because physicians who care for infants and children encounter mothers repeatedly, it is important that they have the knowledge and skills to the detect symptoms of maternal depression. Pharmacotherapy, social supports, psychosocial interventions, cognitive behavioral therapies, and the availability of education and consultation with specialists skilled in the identification, assessment and treatment of behavioral health conditions such as depression will lower associated healthcare costs. New York State should devote waiver resources to establish and enhance interventions available to decrease the consequences associated with this treatable condition.
Collaborative Care is a healthcare philosophy and movement that has many names, models, and definitions that often includes the provision of mental health, behavioral health and substance use services in primary care. Common derivatives of the name collaborative care include: “Integrated Care”, “Primary Care Behavioral Health“, “Integrated Primary Care”, and “Shared Care”.
In New York, our ability to provide Medicaid high-need and uninsured patients suffering from multiple chronic illnesses with access to a cost-effective primary care benefit will both improve patient outcomes and lower overall Medicaid spending. We believe this is best achieved utilizing a true Collaborative Care Model where behavioral health specialists and services are embedded alongside physicians in primary care settings.
The majority of New Yorkers at risk of or living with an untreated behavioral health condition are most likely be seen in a primary care setting, and for this reason it makes sense to utilize waiver funds to ensure behavioral health specialists are stationed in and working alongside our primary care partners. True collaborative care requires behavioral health specialists on staff – not simply on call to a primary care practice where the client is sent away and has to come back for a separate appointment with the behavioral health specialist. In this model the client can move from the doctors office to a waiting specialist where he/she can be evaluated and referred to the appropriate treatment provider.
Expand SBIRT Services
The societal costs associated with undiagnosed / untreated substance abuse cannot be overstated. Making SBIRT services available in Emergency Room settings is a good idea and a great advancement. However, the NYS Council believes there is real value in making this intervention available in a variety of public healthcare settings where clients that have had no prior contact with the substance abuse system typically seek assistance. This might include a primary care physician’s office, public health clinics, homeless shelters, mobile health vehicles, urgent care settings, public schools, etc. We urge the State to consider funding the expansion of SBIRT services to include a variety of settings that provide primary health services. Along with additional funding, we request the State provide mandate relief to permit qualified SBIRT practitioners employed by behavioral health organizations to perform these services on behalf of their employer and bill for these services as the provider of record (“off-site” services).
The New York State Council for Community Behavioral Healthcare (“The Council”) is a 501 (c)(3) statewide membership association representing the interests of 90 mental health and addiction treatment and recovery organizations that provide a vast array of behavioral health services in settings to include: free-standing community agencies, general hospitals, and counties.
For more information contact Lauri Cole, Executive Director at (518) 461-8200.