July 10, 2021

Yesterday afternoon DoH posted its’ proposed Spending Plan associated with enhanced FMAP funds coming in to New York as result of the American Rescue Plan.   Here’s a link to the posting: https://health.ny.gov/health_care/medicaid/redesign/hcbs/enhanced_funding/

Below are the proposals that seem most relevant to our members.  You will note that in many instances the state is using directed payments.  Some of these proposals indicate funds will flow through Medicaid MCOs.  One NYS Council member agency reflected that in the first OMH proposal listed (below) as well as in the proposal that seeks to expand certified and credentialed peer services OMH appears to be proposing a funds flow model similar to that which was used to distribute HCBS Infrastructure Grants.  We’ll need to track this proposal closely and work with state leaders to ensure the problems providers and networks experienced last time are not repeated.

You will note that among the write ups (below) is a proposal that would provide additional funds for BHCCs.  The amount listed is $8M state funds.  We think this will gross to more than $8M ‘all in’.   As you know, the NYS Council hosts and provides support and strategic advice to a group of 17 BHCCs.  Last month, the BHCC Collaborative submitted a formal request to OMH for additional BHCC funding.  We are delighted the BHCCs are included in the Spending Plan.  The NYS Council and the BHCC Collaborative will release a White Paper entitled ‘The Value of Behavioral Health Providers and Their Networks’ on Monday. 

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Improve the OMH Workforce

Funding: $16.7M State Funds Equivalent Lead Agency: OMH
Expenditure Authority: Directed Payment

Background: To effectively provide services to individuals with behavioral health conditions, it is essential to retain experienced and dedicated employees while recruiting new ones. These relatively low paying and highly stressful jobs lead to high employee turnover rates. Targeted loan forgiveness and tuition assistance for current and prospective staff are proven ways to invest in our behavioral health workforce and benefit the individuals we are serving.

Proposal:

Eligible Providers: OMH-licensed mental health providers

Description: This proposal would provide prescribers, licensed practitioners, and program staff in community, rehabilitation, and housing settings to receive targeted loan forgiveness, tuition reimbursement, hiring and signing bonuses, longevity payments, expanded student placements, shift differential pay and expanded retirement contributions. Funds will be implemented through a directed payment preprint to Medicaid MCOs and administered as grants to providers meeting specific qualifications and based on service utilization. Funding would go directly to mental health providers.

Evaluation and Reporting: In accessing these funds, MCOs would report to OMH regarding the specific goals attached to this funding and how the funds have been used to increase the recruitment and retention of prescribers, licensed practitioners, and other program staff. OMH would evaluate each MCO based on their efficiency in using the funding to achieve these outcomes. 

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Improve the OASAS Workforce

Funding: $7.2M State Funds Equivalent Lead Agency: OASAS
Expenditure Authority: Directed Payment

Background: A number of Medicaid-reimbursed services require a high school diploma or equivalent, associate degree, or credential; however, individuals possessing these qualifications can obtain an equal or higher pay without the complexity or stress of these Medicaid service positions. OASAS Medicaid services require a great deal of training and experience to serve the individuals with addiction who need these valuable services.

Additionally, the complex and often co-occurring medical or mental health needs and issues of those with addiction can be physically and emotionally demanding for staff. Staff delivering OASAS services may be early in recovery with limited past or recent employment, or prior criminal history which impacts their employment opportunities. Some may need to work more than one job to support themselves and their families.

All these factors impact the ability to sustain staffing levels and maintain quality services.

Proposal:

Eligible Providers: OASAS certified providers

Description: To sustain staffing levels and maintain services while also allowing for maximum flexibility, OASAS proposes to use a one-time directed payments program which would provide payments to OASAS service providers who offer one or more workforce development strategies Providers who incorporate these strategies would be eligible for one or more payments based on criteria set by OASAS. OASAS will set specific goals for this funding to impact capacity building and lower waitlist, and the funding would be evaluated for specific outcomes. Recommendations for implementation include:

1. Tuition Reimbursement
2. Loan Forgiveness
3. Hiring and Sign-on Incentives
4. Longevity Pay:a. Existing Staff frontline staff and supervisors–one time only
   1. 1 to 3 years
   2. 4 to 6
   3. 7 to 9
   4. 10 years or more

   b. New Hires for frontline staff and supervisor

   1. 6 months
   2. 1 year
   3. 1.5 years
   4. 2 years
5. Training funding inclusive of CEU and professional licenses
6. Differential Pay for nights and weekends
7. Retirement contributions, extending health insurance benefits, or other fringebenefits for staff.

Evaluation and Reporting: Eligible providers would report to OASAS regarding the specific goals attached to this funding and how the funds have been used to build capacity and reduce waitlists. OASAS would evaluate each eligible provider’s use of the funding to achieve these outcomes. 

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Increase Medicaid Rehabilitation Rates for OMH Community Residence Programs

Funding: $6.9M State Funds Equivalent
Lead Agency: OMH
Expenditure Authority: State Plan Amendment

Background: Funding for Community Residence programs has been historically challenging, making it difficult for providers to hire and retain an adequate number of staff to safely operate these programs.

Proposal:

Eligible Providers: OMH-licensed Rehabilitation for Community Residence providers.

Description: Rate increases will be targeted towards direct care staff costs in order to meet critical challenges to workforce recruitment and retention, which are needed to operate these programs more effectively and to address the critical workforce shortages that currently exist. Funding will be disbursed through rate increases paid across FFS Medicaid claims as services are provided to eligible Medicaid recipients.

Evaluation and Reporting: In accessing these funds, eligible providers would report to OMH regarding the specific goals attached to this funding and how the funds have been used to retain staff needed to safely operate these programs. OMH would evaluate each eligible provider’s use of the funding to achieve these outcomes.

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Enhance the Children’s Services Workforce

Funding: $5.1M State Funds Equivalent Lead Agency: DOH
Expenditure Authority: Directed Payment

Background: A number of Medicaid services require a high school diploma or associate degree; however, individuals possessing these qualifications can obtain equal or higher pay without the complexity or stress of these Medicaid service positions. Children’s Medicaid services require a great deal of training and experience to serve the children and youth who need these valuable services. Additionally, the complex needs and issues that children and youth present to service providers are physically and emotionally demanding. These factors are compounded by relatively low reimbursement rates and many staff work two jobs, which impacts the ability to sustain staffing levels.

Proposal:

Eligible Providers: Children and Family Treatment and Support Services (CFTSS), HCBS, Article 29-I Foster Care Agencies (29-I), and Health Homes Serving Children (HHSC).

Description: Due to provider diversity and differing needs of agencies regarding staffing, as well as to ensure the maximum ability to maintain or build service capacity, a model is recommended that would offer eligible providers flexibility in utilizing the enhanced FMAP. Specific goals will be attached to this funding to impact capacity building and eliminate waitlists, and the awardees will be evaluated for specific outcomes.

To that end, the following list of workforce development strategies will be offered for qualifying providers to access through a Children’s Services Workforce Development Fund:

1. Tuition Reimbursement
2. Loan Forgiveness
3. Hiring and Sign-on Bonuses
4. Longevity pay for existing frontline staff and supervisors
5. Support of student placements and internships to create a workforce pipeline
6. Training funding inclusive of Continuing Education Unit(CEU),professionallicenses, and maintenance of professional certifications
7. Evidence Based Practices (EBP): maintenance of certification and fidelity to themodel
8. Provide start-up funds for evidence-based program modalities
9. Differential Pay for nights and weekends

10. Retirement contributions, extending health insurance benefits, or other fringe benefits for staff

Evaluation and Reporting: In accessing these funds, eligible providers would report to DOH regarding the specific goals attached to this funding and how the funds have been used to build capacity and eliminate waitlists. DOH would evaluate each eligible provider’s use of the funding to achieve these outcomes. This evaluation would be part of the quarterly reports submitted by DOH to CMS regarding use of this funding.

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Expand Training and Implementation Support for Evidence Based Practices (EBPs)

Funding: $4M State Funds Equivalent 

Lead Agency: OMH
Expenditure Authority: N/A

Background: OMH has identified EBPs that serve as the best methods to ensure quality of care, community inclusion and the ability of the individuals we serve to lead rich, full, satisfactory lives, including meaningful interpersonal relationships and employment. While OMH encourages and supports these practices, better training and educational resources are needed to support a workforce able to provide such practices more robustly.

Proposal:

Eligible Providers: Funding is allocated to Training and Technical assistance agencies with expertise in EBP dissemination and to the SUNY system or other institutions of higher education.

Description: OMH has undertaken a significant system redesign initiative to foster provision of evidence-based practices, recovery-oriented care, and psychiatric rehabilitation services. Under this redesign, OMH must expand training and implementation support in EBP, including diagnosis and treatment across the provider continuum, with incentivization of EBP uptake and fidelity, with particular focus on the assessment and treatment of co-occurring disorders, treatment of marginalized and underrepresented demographics, and specialty clinical populations (including but not limited to clinical high risk for psychosis and obsessive-compulsive disorder), leadership training, addressing provider costs associated with training attendance, collaboration with State University of New York (SUNY) in a Certified Rehabilitation Counselor (CRC) or Masters in Psychiatric Rehabilitation program, and development/expansion of rehabilitation programs and services with in-person training. Funding will be dispersed via existing or new contracts with Training and technical assistance agencies and SUNY or other institutions of higher education.

Evaluation and Reporting: In accessing these funds, eligible providers would report to OMH regarding the specific goals attached to this funding and how the funds have been used to expand the knowledge base of personnel employed by providers

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Expand Recruitment and Retention of Culturally Competent, Culturally Responsive and Diverse Personnel
Funding: $4M State Funds Equivalent
Lead Agency: OMH

Expenditure Authority: N/A

Background: Ethnic and racial minorities are very under-represented in the mental health workforce, especially in the professions and disciplines that require advanced degrees or education-based certifications. This under-representation is one of the drivers of mental health disparities for marginalized populations. Minority providers are more likely to meet the needs of underserved populations and a diverse workforce results in greater patient/client satisfaction, engagement, and retention in care. Additionally, the mental health workforce is experiencing shortages of clinicians who are multilingual – further driving disparities in access, quality, and treatment outcomes for individuals who are limited English proficient.

Proposal:

Eligible Providers: OMH-certified mental health providers that demonstrate the specific diversity goals. Funding would also go to the SUNY/City University of New York (CUNY) educational institutions for tuition reimbursement and loan forgiveness programs.

Description: OMH would complete an environmental scan of the current mental health workforce to identify areas of under-representation, both geographically and demographically, with the goal of ensuring an adequate level of demographic and linguistic representation within the field. Based on this analysis, the Agency will provide funding to SUNY/CUNY schools based on geographic location and programs offered to underserved students to complete study in fields with the highest identified need. These funds would be used to fully or partially support educational attainment and credentialing.

Students approved for acceptance in this program will certify that they will serve in the mental health field in New York State in areas identified as underserved using population health approaches for a defined period of time. To support retention in the field, loan forgiveness will be awarded to diverse/multilingual individuals in the mental health workforce and those working in underserved communities if they agree to continue to work in the field in underserved communities for a pre-determined amount of time. Additionally, funds will be allocated to SUNY/CUNY schools to support educational attainment for diverse and multilingual individuals working in the field with the goal of career advancement and retention.

Funds will be administered as grants to providers meeting specific qualifications. Funding would also go to SUNY/CUNY educational institutions for tuition reimbursement and loan forgiveness programs for diverse individuals.

Evaluation and Reporting: In accessing these funds, entities would report to OMH regarding the specific goals attached to this funding and how the funds have been used to increase the recruitment and retention of culturally competent staff. OMH would evaluate each entities’ use of the funding to achieve these outcomes. This evaluation would be part of the quarterly reports submitted by OMH to DOH regarding use of this funding.

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Expand Certified and Credentialed Peer Capacity

Funding: $4M State Funds Equivalent Lead Agency: OMH
Expenditure Authority: Directed Payment

Background: Peer Workers working in a variety of settings across our system of care do not have a centralized entity that provides leadership and support for the growth and advancement of the Peer Workforce. The majority of the helping professions employed in mental health settings belong to professions that already have mentoring components built into their education and development. The Peer Workforce is growing exponentially with the demand for Peer Services and Peer Support Services are in high demand across all OMH services due to their proven outcomes of treatment engagement and better experiences in care. The demand for Peer Support Services far exceeds the current certified and credentialed workforce capacity and infrastructure to support the Peer Workforce growth and development are needed to ensure these critical services are available to New Yorkers struggling with mental illness.

The Peer Mentoring Network would match Peer Workers with Peer Mentors from across the State. An emphasis will be placed to support Peer Workers representing marginalized communities to assume leadership roles. As the demand for peer- delivered services grows, many clinical (or non-peer-run agencies) are looking to hire Peer Workers to work in traditionally clinical services. Many of these agencies do not have leadership within their organization to create and design infrastructure to support successful inclusion of Peer Workers, which leads to turnover, lack of clarity of the full impact of what Peer Workers can do, and supervisors that are not equipped with the skills or training to supervise Peer Workers.

The Peer Workforce has access to a core curriculum to help enable them to work in our public mental health system; however, more specialized training is needed. These specialized training programs can be parenthetic to existing peer certification and credentials. Specialized areas include (but are not limited to): forensics, crisis, older adults, transition age youth, and LGTBQIA+.

Proposal:

Eligible Providers: Mental health providers that are employing and/or recruiting peers, training and certification entities, and other vendors with subject matter expertise in the provision of Peer Support and Peer Delivered Services.

Description: New York proposes to expand certified peer capacity (inclusive of adult peer, youth peer, family peer) in OMH programs through investment in resources for recruitment, education/training, and career pipeline investments. As New York continues to grow its capacity to provide Peer Support Services across the OMH system of care, agencies that currently do not offer Peer Support services need additional guidance on how to implement these services effectively in their settings. The creation of a New York State Peer Workforce Advancement and Mentoring Network and a Peer-Delivered Service Inclusion Center of Excellence will help OMH in achieving these goals. Additionally, training expansion and capacity to best support underserved and emerging populations, such as justice-involved individuals and older adults with mental illness will be needed to ensure the Peer Workforce is adequately equipped to provide effective services to these groups.

Funds will be implemented through a Directed Payment to Medicaid MCOs and administered as payments to providers based on Peer Services utilization when they meet specific qualifications. Funding would go directly to mental health providers that are employing and/or recruiting peers, training and certification entities, and other vendors with subject matter expertise in the provision of Peer Support and Peer Delivered Services.

Evaluation and Reporting: In accessing these funds, MCOs would report to OMH regarding the specific goals attached to this funding and how the funds have been used to expand the number of certified and credentialed peer workers working in mental health settings across New York State. OMH would evaluate each MCOs use of the funding to achieve these outcomes. This evaluation would be part of the quarterly reports submitted by OMH to DOH regarding use of this funding.

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Adjust Residential Addiction Treatment Services Rate

Funding: $22M State Funds Equivalent
Lead Agency: OASAS
Expenditure Authority: State Plan Amendment

Background: OASAS expanded access to residential services in 2015 with the addition of these services in the managed care benefit package. This change was made to better align the OASAS continuum of service delivery to meet the needs of patients suffering from addiction, including patients suffering from severe addiction and higher prevalence of co-occurring mental health conditions. Providers receive three years of supportive funding as they transition to the new residential service model, which, for most (if not all) providers, will end before 2023. This loss of funding was compounded by COVID-19, and associated safety protocols, which resulted in decreased census at a time when residential services were especially necessary.

Proposal:

Eligible Providers: Residential Addiction Treatment providers licensed or certified by OASAS.

Description: To maintain crucial services, New York proposes to temporarily increase rates for existing residential services and to increase services for individuals in early recovery to assist with reintegrating into their community by incorporating the residential reintegration service into the Medicaid benefit package.

1. Apply the10%rate adjustment to OASAS residential addiction treatment services; and
2. Utilize enhanced FMAP monies to support necessary staffing and start-up costs for OASAS residential reintegration addiction treatment services through enhanced Medicaid rates once incorporated into the Medicaid benefit.

Evaluation and Reporting: Eligible providers would report to OASAS regarding the specific goals attached to this funding and how the funds have been used to build capacity and reduce waitlists. OASAS would evaluate each eligible provider’s use of the funding to achieve these outcomes.

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Expand and Implement HCBS and Community Oriented Recovery and Empowerment (CORE) Services
Funding: $12.5M State Funds Equivalent
Lead Agency: DOH, OMH

Expenditure Authority: Directed Payment

Background: Adult behavioral health HCBS services have had low utilization since inception due to barriers in access limiting provider referrals and their ability to serve the target Health and Recovery Plan (HARP) population. The State has made changes in these regulatory barriers, but will need funding to ensure start-up, increase access, and address workforce challenges.

Proposal:

Eligible Providers: Adult CORE providers

Description: HCBS CORE services expansion and implementation support aimed to complement of current infrastructure funding via enhanced rates, marketing, and outreach funds; expanded provider capacity via workforce funding; and improved access and engagement via transportation and telehealth infrastructure. Ensuring access to critical treatment and rehab services for individuals identified as having significant behavioral health need and service utilization (HARP enrollees). Funding will be disbursed through rate increases paid across MCO Medicaid claims as services are provided to eligible Medicaid recipients. Funding will be allocated to Adult CORE providers.

Evaluation and Reporting: In accessing these funds, eligible providers would report to OMH regarding the specific goals attached to this funding and how the funds have been used to implement and expand access to Adult BH HCBS and CORE services. OMH would evaluate each eligible provider’s use of the funding to achieve these outcomes.

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Extend Short-Term Support for Behavioral Health Care Collaboratives

Funding: $8M State Funds Equivalent Lead Agency: OMH
Expenditure Authority: Directed Payment

Background: Due to market circumstances and timing, including the COVID-19 pandemic, additional funding is needed to ensure New York’s value-based payment goals for behavioral health are achieved and Behavioral Health Care Collaboratives (BHCCs), which have largely been structured as New York independent practice associations (IPAs, or BH IPAs), can maintain and enhance operations, while health systems and MMC plans reopen network development operations.

With additional funding and time, BH IPAs can forge or expand relationships with MMC plans and health systems to meaningfully participate in risk-sharing arrangements sought by alternative payment methodology and VBP mandates. This funding will create and enhance partnerships addressing populations disproportionately impacted by the COVID-19 pandemic and bring innovation to behavioral and physical health integration. BH IPAs are positioned to lead the Statewide response to increased mental health and substance use challenges resulting from the COVID-19 pandemic and preserve the BH safety-net system. These entities have been screening for and responding to identified social determinants of health needs and are well-positioned to serve populations historically underserved by the traditional health care system and in existing VBP arrangements.

Proposal:

Eligible Providers: Existing BHCCs operating as BH IPAs

Description: Beginning in 2018, New York State invested $60M to develop BHCC service networks across the behavioral and physical health continuum to prepare the BH system to engage VBP and increase availability of integrated clinical services. Funds supported BH provider system culture change, moving from competition to collaboration across networks.

BH providers in these BHCC networks gained knowledge and insight about how to define and measure the value BH brings to the overall health care system and managed care organizations. Most of these provider networks incorporated as BH IPAs, in order to enter contract arrangements. These BH IPAs developed significant infrastructure to drive integrated care, measure and manage data across networks, and improve service delivery across the behavioral and physical health spectrum.

This additional development funding would allow for BH IPAs to continue their pre- pandemic work. 

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Support the Transition to Article 29-I Health Facility Core Limited Health Related Services

Funding: $8.6M State Funds Equivalent
Lead Agencies: DOH, OCFS
Expenditure Authority: State Plan Amendment

Background: New York Medicaid-covered children and youth in the care of Voluntary Foster Care Agencies (VFCAs) or placed in foster homes certified by LDSS are in the process of being enrolled in MMC Plans on July 1, 2021, including Mainstream MMC plans and HIV Special Needs Plans (HIV-SNPs), unless they are otherwis excluded or exempt from mandatory MMC. As a result of the pandemic, the transition date has been significantly impacted.

Access to comprehensive, high quality health care is essential to children and youth placed in foster care. Children and youth in the foster care system have higher rates of birth defects, developmental delays, mental/behavioral health needs, and physical disabilities than children and youth from similar socio-economic backgrounds outside of the foster care system. Children and youth in foster care have a high prevalence of medical and developmental problems and utilize inpatient and outpatient mental health services at a rate 15 – 20 times higher than the general pediatric Medicaid population. The impact of the trauma these children/youth experience is profound.4 For this reason, it is essential that there be immediate access to services upon a child or youth’s placement in foster care, and no interruption in the provision of ongoing services as a result of this transition.

All Licensed Article 29-I Health Facilities are required to provide, or make available through a contract arrangement, all Core Limited Health-Related Services. The five Core Limited Health-Related Services play a vital role in assuring all necessary services are provided in the specified time frames; children, parents and caregivers are involved in the planning and support of treatment, as applicable; information is shared appropriately among professionals involved in the child’s care; and all health-related information and documentation results in a comprehensive, person-centered treatment plan. Core Limited Health-Related Services are reimbursed with a Medicaid residual per diem rate paid to 29-I Health Facilities on a per child, per day basis to cover the costs of these services. The services include: Skill Building (provided by Licensed Behavioral Health Practitioners (LBHPs) as described in Article 29-I VFCA Health Facilities License Guidelines and any subsequent updates); Nursing Services; Medicaid Treatment Planning and Discharge Planning; Clinical Consultation and Supervision Services; and VFCA Medicaid Managed Care Liaison and Administrator services.

4 American Academy of Pediatrics Task Force on Health Care for Children in Foster Care, Fostering Health: Health Care for Children and Adolescents in Foster Care. (New York: American Academy of Pediatrics, 2005).; and Mark D. Simms, Howard Dubowitz and Moira A. Szilagyi, “Health Care Needs of Children in the Foster Care System,” Pediatrics 2000;106(4 Suppl):909- 918.; and Dutton M Fiori T, Karl A, Sobelson M. Medicaid managed care for children in foster care. In: Fund Medicaid Institute at United Hospital, editor: UHF; 2013.

The per diem rates established for these services were established prior to the pandemic and do not take into account the significant impact of the pandemic on children in the care of the 29-I Health Facilities, or the additional administrative burden on the providers of the delays in the transition of this population and the 29-I services into managed care.