NYAPRS Note: Here’s our best sense of where things currently stand with regards to the extraordinary number of simultaneously moving state policy and programmatic initiatives that NYAPRS members and staff have been helping to inform and to shape.
Health and Recovery Plans (HARPs)
- It’s seems possible that, given the complexity of how all of these moving parts effect each other and how they require ongoing approvals by CMS, the New York City start date for the HARP initiative might be delayed a few months. That would, in turn, move us back a few months from the July start date for upstate and Long Island.
- This week, the state gave more detailed feedback and recommendations to the health plans who have applied to operate a HARP in New York City. A brief delay would also provide those plans with more time to make those changes and preparations.
- NYAPRS is continuing to work with health plan representatives and advocates to best collaborate and advocate for an optimal HARP transition and operation, building on a NYC-based presentation 10 of our members gave to members of the Health Plan Association earlier this year, in collaboration with ASAP, the Coalition and MHANYS.
1915.i Home and Community Based Services
- In September, we are expecting that the state will release revised definitions and more details about how non-Medicaid funded services (like peer run, rehabilitation, clubhouse, employment, education, crisis and transportation) will transition to play the major role in the HARP design for which NYAPRS has long advocated.
- Central to this process, the state should also be providing details about the designation process by which the state will deem a provider’s non-Medicaid services as eligible for Medicaid reimbursement as a 1915.i service.
- Around this time, the state will also be releasing draft rates that will guide 1915.i providers and plans in their development of contracted service agreements. While the state will be paying for these services at these rates for the first two years of the HARP initiative, the plans will draw from their capitated per member per month monies to pick up these costs during the 3rd year and thereafter.
- Certain designated 1915.i providers (those who have not previously billed Medicaid) can then prepare to apply for state funding to help ramp up their readiness to bill Medicaid under the HARP initiative, including the appropriate management, IT, corporate compliance, HIPAA compliance et al. NYAPRS member agencies should be increasing their efforts to reach tentative network agreements with area HARP health plan applicants to demonstrate that they will have the ‘business’ to warrant such state startup funding investments.
- NYAPRS members and our colleagues worked hard this past budget session to win approval of the $30 million allocation to help 1915.i providers to successfully transition and operate within the HARP environment. It appears that a portion these funds will be available to help boost provider readiness and that the remainder will actually pay for the aforementioned first 2 years of 1915.i service reimbursement for which the state will paying.
- NYAPRS staff have been supporting distinct groupings of member agencies to best prepare for the HARP environment, including PROS and clubhouse programs. Our Peer Services Work Group is about to re-launch its efforts in this area in the coming weeks. These groups have and/or will continue to meet with the appropriate state and NYC officials to help each of us to best inform and influence these efforts.
- NYAPRS staff are also sitting on various state work groups to advance our agenda, including the recently formed MRT Social Determinants of Health work group and subcommittees relating to employment and transportation. We remain a member of the MRT’s Behavioral Health Work Group. Finally, we’ve also been attending meetings regarding the Balancing Incentive Program (BIP) and Medicaid Accountable Care Organizations (ACOs).
- Also, NYAPRS has been working with OMH, Columbia University and DOHMH on the development of a design to launch a several year self-directed care pilot that will ultimately inform how self-directed care will become a widely available 1915.i service going forward.
DSRIP (Delivery System Reform Incentive Payment)
- In a recent meeting with state Medicaid officials and advocates, NYAPRS pressed for a state commitment to consider non-Medicaid providers that are serving more than 35% Medicaid beneficiaries as DSRIP safety net providers, to raise their stature to be considered an essential element within the regional DSRIP Performing Provider Systems (PPS). Medicaid officials and advocates agreed that this argument is strengthened by the fact that providers of designated 1915.i services will soon be Medicaid providers under the HARP. We understand that DOH and CMS will be considering this request in the coming weeks.
- Towards that end, we have advocated that OMH provide those groups with an up to date list of eligible non-Medicaid providers, along with Patient Characteristic Survey date that could substantiate claims that these providers are indeed serving the required 35+% Medicaid beneficiaries.
- A non-Medicaid provider appeals process to be considered a DSRIP safety net provider was not included in this week’s re-opening of the application and appeals process. We are hoping and expecting that the state will create a process by which designated 1915.i providers can seek an ‘exception’ to be considered such a safety net provider.
Managed Care Readiness Assistance
- The state recently provided funding to the McSilver Institute for Poverty, Policy and Research to offer an array of training and technical assistance to help ready behavioral health providers for the HARP and managed care environment. As a previous partner to McSilver’s state funded Clinic Technical Assistance Center (CTAC), NYAPRS will also be working as a partner within this MCO TAC, looking especially to help inform and extend these efforts to non-Medicaid 1915.i providers.
Member Assistance
Speaking of ramping up, NYAPRS has been taking our member assistance package to another level to help our members be best informed and supported during this extraordinary period. Here are some examples:
- We are working with our members to compile a downloadable and ‘living’ compendium that will help educate health plans, hospitals, DSRIP leads, health homes, FQHCs and others about the needs of people with serious behavioral health conditions and service approaches that best address those needs. This “Behavioral Health Services Continuum” will be displayed on a NYAPRS web portal which will indicate and provide interactive links to assist users to identify NYAPRS member providers of the behavioral health services in every region of the state. We are hoping this will help support and maybe ease some of your efforts in educating new payers about your services.
- Please come join the next webinar of our Medicaid Redesign Learning Collaborative, entitled “Where Do I Fit in DSRIP?: Putting The Pieces Together’ at 10:00-11:30 am on Wednesday August 27, 2014 with Briana and Edye.
- Briana and I are beginning to work with our regional coordinators to plan and schedule another round of our annual Regional Forums. This round will include up to date clear presentations and discussions on the MRT initiative and also gather priorities for the 2015 Legislative and Budget sessions.
- Finally, don’t miss our NYAPRS 32nd Annual Conference, ‘Recovery Moves to the Mainstream,’ to be held September 17-19 once again at the Hudson Valley Resort in Kerhonkson. The program is chock full of state and national expert presentations that will cover all of the above issues and a ton more! Check out the program details at http://www.nyaprs.org/documents/PrelimProgram_001.pdfregistration info at https://rms.nyaprs.org/event/?page=CiviCRM&q=civicrm/event/info&reset=1&id=13.
Stay strong…know that we’re ultimately heading towards the ‘change of a lifetime’ and that NYAPRS will be there with you every step of the way! You can always reach us at brianag@nyaprs.org and at harveyr@nyaprs.org