Serious Access to Care/Network Adequacy Challenges
  • Need to address serious shortage of inpatient beds for children/youth
  • Need to address already significant and growing waiting lists for care across the state
Reimbursement Reform Recommendations
  • Implement COLA @8.5% (July 2022 CPI)
  • Implement Outpatient Rate Reform proposal
  • Expand the federal CCBHC Demo for eligible NYS Outpatient Clinics
  • Confront discriminatory disparity between what commercial insurers reimburse. Reimbursement is often 50% of the state mandated Medicaid APG government rate for the same services.
  • Rate increases for Programs and Services that are not sustainable to include: OASAS Part 820 Stabilization and Scattered Living levels of care; OASAS Part 819 Scattered Living levels of care, OASAS Peer Services

NYS Council Member Survey Result:  Approximately 50% of survey respondents with commercial contracts receive 50% or less of the Medicaid APG government rate, for the same services.

Recommendations to Address Workforce Crisis
  • Expedite SED Diagnostic Privilege implementation per enacted 2022 law
  • Implement Administrative / Regulatory Relief in the pre-employment process required to onboard new employees – often takes months and Central registry looks back 28 years!
    • Discontinue discriminatory hiring practices that limit who we can hire (CPS history, criminal hx
    • Implement State hosted Central Registry for clearances and develop a crosswalk for all state agencies to avoid redundant checks of potential employees and streamline process
    • Justice Center must expedite closing unfounded cases in areas of state with significant Workforce shortages
  • Adopt Journeyman approach/accept life experience as relevant job experience

NYS Council Member Survey Result:  The most frequent response to the question of how long it takes the agency to onboard new staff is 1-2 months with top impediment being clearance of CPS Registry followed by mandatory and often duplicative fingerprinting requirements, Justice Center clearances, and Background Check requirements.

In a recent statewide survey of various BH Programs and Services, we found that the ‘new hire’  rate is nearly identical to the number of staff that left our employment in 2022.

Recommendations to Address Persistent Medicaid Managed Care/Commercial Insurance Issues
  • State must address commercial rate disparity that puts undue pressure on Medicaid APG government rates
  • The State must greatly enhance surveillance, monitoring and enforcement activities by OHIP and empower OASAS and OMH to perform more of these tasks
  • Need robust access to Medicaid and other data held by health plans for purposes of VBP contracting and other alternative payment methodologies
  • Re-negotiate Model Contract language that currently permits MCOs to skirt contractual and other mandated responsibilities

NYS Council Member Survey Result:  1/3 of all respondents’ report that currently they are waiting for delayed reimbursement from an MCO/s.  The most frequent response to the question as to how long the agency has been waiting for the payment/s is over 9 months.  Range for amount owed to provider is between $10k to $200k. 

Recommendations to Support Children, Youth/Families
  • CFTSS rate enhancement should be made permanent
  • Public Health Law should be revised to ensure there are interim intensive supports available in local communities to address instances in which a hospital BH unit/s closes beds/services
  • Increase current percentage of federal dollars coming into NYS for children’s system of care to 30%
Recommendations to Support OASAS Primary Prevention Programs and Services
  • 10% increase to all OASAS Primary Prevention contracts to address reimbursement that has been stagnant for over 20 years, to assist with workforce shortages, rent increases and operating expenses
  • Funds to conduct evaluation of OASAS primary prevention programs
    • Develop EBPs for Primary Prevention services
    • Current grant cycle (two years) is too short a window to evaluate outcome
    • Funding needed to permit innovation in this service line
    • Inability to pay staff at higher wages for weekend and holiday events


For more information about the NYS Council, please contact Lauri Cole, Executive Director at 518 461-8200 or lauri@nyscouncil.org