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:
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
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
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!