Proposed Changes to Adult HCBS Program

July 2, 2020

The public notice discussing proposed changes to the adult HCBS

Program is at the link (below) on page 77.  There is an ongoing public

comment period with responses due mid-August.    Here’s the link:

On May 22 we sent all members an email summarizing a discussion we had

with OMH leads in which they described some changes they wish to make

to the OMH service delivery system including changes to the adult HCBS

Program that are intended to streamline access to these services for

New Yorkers seeking assistance.

Here’s the communication we sent on 5/22/2020:

Good afternoon,

Today, during a call hosted by OMH leads for provider association

leads, I asked Bob Myers to discuss some of the thinking at OMH and

the more specific tasks and activities going on inside the Office in

an effort to advance our system of care given the enormous changes

that have occurred as result of the COVID-19 crisis as well as the

plans that were in the works prior to this crisis.

Continued Use of Telehealth Modality

OMH officials were not able to provide a specific date that they will

issue guidance to the field around the continuation of

telehealth/telephonic practice in OMH programs and services.  OMH is

currently preparing a list for the Governor’s Office of recent

Executive Orders that would need to be extended to allow continuation

of telehealth / telephonic flexibility that have been granted during

the emergency period.  It sounds to me as if leads at OMH are fully

committed to advancing our requests for both extensions and permanent

orders that will permit providers to continue to offer services using

these modalities.  In both cases (an extension and/or permanent

changes) we should expect OMH to issue accompanying guidance that

addresses clinical aspects associated with the continuation of these

services including when you can use them, etc.  Ultimately, decisions

around permanency of the emergency regs, on a variety of topics, will

depend on several factors including the data and interviews OMH is

currently conducting with providers around the state.  These

interviews include such topics as how the introduction or expansion of

telehealth/telephonic modalities has impacted access to care and early

outcomes.  Note:  These discussion have gone beyond the topic of

telehealth/telephonic to cover other changes providers have

experienced and regulatory changes they have appreciated during this

time period.

OMH System Reform

In addition to the telehealth discussion, we also talked about reform

activities OMH is currently engaged in to envision and implement a

more accountable system of care, during this crisis and beyond.  Bob

Myers discussed the following discussions going on at SOMH, several of

which have moved beyond just discussion as of today:

1) Move OMH Outpatient Clinic Services out of the (federal) Clinic

Option to the Rehab Option, thus allowing more flexibility in clinic

services to include off site services and peer services (this is a

concrete plan that is moving forward and will require a SPA amendment

to CMS).

2) Reform the model for HCBS services to more of a direct care

rehabilitation service that does not rely as heavily on Health Home or

Care Management assessments in order to access immediate direct care.

3) Find a way to connect Health Home+ services to the rest of the

system in a manner that might resemble the ICM model of care.

4) Look at PROS and re-constitute it to more of a mobile service with

the opportunity to offer virtual technology for PROS group services.

5) Answer the question as to how providers can effectively deliver

rehabilitation services telephonically.

6) Find a way to pull these services together in an integrated network

of care through a variety of platforms including (but not limited to)

BHCC/IPA networks,  CCBHCs and CCBHC extension grant agencies that

already operate most of the services discussed here, and find a way to

incentivize certain provider behaviors within an integrated model of


Caveats:  All of these plans will be impacted by the bottom line,

which is that OMH only has the money it is working with now to make

all these changes, and much will depend on whether State cuts (as

discussed by the Governor in the Financial Plan he outlined about a

month ago) include Medicaid Program cuts, and major local assistance

reductions that impact our system.

The discussion included more than these two items.  I will continue to

share information from the conversation over the weekend.

Wishing everyone a health and safe weekend.

Let us say it again.  We are so proud to represent you!