CHP: Takeaways from MRT 1115 Waiver Proposal

August 31, 2021

The article below appears in today’s Crain’s Health Pulse, (8/31)

Here is a link to the website for COPE Health Strategies, one of the consulting firms quoted in the article.  You can read COPE’s  1115 waiver analysis in full (directly below).  Last week we sent you an analysis of the 1115 Waiver Concept Paper from Kalin Scott at Helgerson Solutions Group.

Key takeaways from the Medicaid redesign team’s latest waiver proposal

The state on Thursday published its $17 billion Medicaid waiver proposal, which seeks to address health disparities exacerbated by Covid-19.

Unlike its Section 1115 predecessor, the Delivery System Reform Incentive Payment, or DSRIP, the new waiver aims to integrate social services and the social determinants of health into the fabric of Medicaid.

The proposal targets four areas: a more resilient health care delivery system that reduces racial disparities and integrates social care; support for the long-term-care population; a strengthened behavioral health system able to withstand future crises; and the creation of a statewide digital health and telehealth infrastructure.

The new proposal creates two entities, health equity regional organizations, or HEROs, to streamline efforts on the providers’ side, and social determinant of health networks, or SDHN, to bring together community-based organizations. These two parallel entities will work together to ensure health care, social services and equity can be delivered simultaneously.

With the two overarching entities in place, advanced value-based payment arrangements to managed-care organizations can be set up to support mid- to long-term integration of health care and social services.

Nonmedical providers historically had not been deeply integrated within health care settings, said Allen Miller, principal and CEO at Cope Health Solutions, a Bryant Park–based health care consultancy.

“You might have a [physician association] or large medical group that contracts with a plan for primary and specialty care,” Miller said. “You don’t necessarily have a highly defined network of nonmedical providers that provide those services.

This integration represents a commitment that says, “Let’s stop making it a special project. Let’s integrate this into the core business model of health care now,'” Miller said.

The focus of DSRIP, implemented by former Gov. Andrew Cuomo in 2014, had been on managing costs via incentives to providers, largely hospitals. The role described for HEROs is an improvement over the previous model, but it is unclear how they are to be regionally organized and how the state will ensure the same regional organization as the proposed social determinants of health networks, said Zach Hennessey, vice president of neighborhood health at Public Health Solutions, a Tribeca-based nonprofit organization.

“In NYC, this is especially tricky, where the risk of overlapping governing organizations threatens to replicate the fragmentation of the health care system,” Hennessey said.

Populations requiring specialized long-term care, including those in psychiatric facilities, nursing homes and facilities for people with intellectual or developmental disabilities, had been left devastated by the pandemic. The paper proposes more supportive housing that would help avoid institutionalization of these individuals.

To shore up behavioral health resources for future large-scale disasters, the Health Department proposed investments into pandemic response and workforce incentives and training as well as improvements to IT and infrastructure.

Finally, with health care moving to virtual and remote delivery during the pandemic, the proposal suggests creating a statewide digital health and telehealth infrastructure. The state will establish funds to ensure equitable access to digital tools and seek ways to streamline telehealth reimbursement.

“While technology is critical to success, we will need the state to use its power to ensure CBOs do not end up being required to use multiple, competing platforms in a single region like NYC, as they did during DSRIP,” Hennessey said.

Overall, although they felt further clarity would have been appreciated, stakeholders approved of the proposal.

A spokesman for the Greater New York Hospital Association said the organization supports the concept paper’s goals. The association, in conjunction with health care union 1199SEIU, will work with the state to ensure the eventual granted federal funding will be able to meet the needs of health organizations and the communities they serve, he said.

“If we revert to pre-pandemic policies in health and human services, we will not have learned the lessons of Covid-19, and we will gain little in terms of health equity or community resilience,” Hennessey said. —Shuan Sim and Maya Kaufman