New York’s $2.75 billion Medicaid COVID-19 ask: an overview
New York State’s Medicaid program submitted a $2.75 billion request to the federal Centers for Medicare and Medicaid Services (CMS) today, to respond to the COVID-19 pandemic, proposing to repurpose the infrastructure built under the state’s Delivery System Reform Incentive Payment (DSRIP) program and support rapidly “pivoting and reconfiguring aspects of the State’s health care delivery system.”
What does this significant ask mean for New York’s health ecosystem?
· $2.75B in new federal funding for the period March 1, 2020 — March 31, 2021. (Funding would expire either on the state’s proposed end date of March 31, 2021, or 60 days after the currently declared public health emergency ends.)
· Preserving the Safety Net: Emergency Capacity Assurance ($1.2B): Investments to support essential community providers and institutions involved in COVID-19 response, serving Medicaid and uninsured individuals, and facing sustainability challenges
· Rapid Facility Conversion ($650M): Investments to support rapid facility conversion at a local level to meet demand in the public health emergency
·Regional Coordination and Workforce Deployment ($900M): new funding for the state’s Performing Provider Systems (PPSs) to support regional coordination, deploy telehealth infrastructure, expand adoption of promising practices related to COVID-19 response (tying back to the state’s recently denied DSRIP renewal request), and support workforce redeployment efforts to enhance local capacity in a public health emergency. PPSs will also work together across the state to coordinate efforts and identify the best ways to repurpose the state’s PPS infrastructure to respond to the COVID-19 pandemic.
· Additionally, the state seeks regulatory flexibilities to support the health care delivery system’s response to COVID-19, shifts the requests made in its 1335 waiver to this new application, and seeks extension of up to 12 months of all the current terms and conditions of its MRT Waiver (currently set to expire in March 2021.)
· While this application focuses specifically on the state’s needs related to the COVID-19 pandemic, the state references the upcoming MRT Waiver renewal and teases a future concept paper with the goal of designing the ‘delivery system of the future’ aligned with value-based payment goals and learning from the lessons of COVID-19.
The 1115(a) emergency waiver request was submitted in response to a March 2020 opportunity for states made available by CMS due to the national public health emergency declaration. The state’s submission includes both a letter and full application detailing the need for federal investment, outlining the intended purpose for the funds, and how providers will be able to access those funds if approved by CMS.
Approval of the funding would allow New York to design “a more flexible, strategic, community-focused health care system that responds dramatically more effectively in times of a national or state health emergency,” expanding on the strong foundation that DSRIP built.
What’s next?
If CMS approves New York’s request, the state would kick into high gear to make funding available, developing an application process for the Preserving the Safety Net: Emergency Capacity Assistance funding, publish requirements on its website, allow for a 10-day application period, and make all determinations of awards. Rapid Facility Conversion would follow a similar approach, and the state would work with local counties, public health organizations and facilities to distribute funding.
Regional Coordination and Workforce Redeployment funding for PPSs would be made available through a fast-tracked application and approval process. All 25 PPSs across the state would be eligible to submit a regional coordination plan, and those with strong community-based organization partnerships and have an ‘inclusive’ provider network will be given ‘special consideration and weighted appropriately’ in award allocations. While some regions have multiple PPSs, the state acknowledges that ‘overlapping coordination will be allowed’, in the interest of reaching the various communities served by each PPS. 50% of funding would be available upon approval of a PPS’s coordination plan, and the remaining funds would be allocated based on performance. PPS reports would be submitted at both the 45- and 90-day marks, and any unused funds may be reallocated to other PPS based on emerging needs.
Before any of this can happen, CMS must review and determine whether to approve the state’s request. Due to the public health emergency, CMS has not required traditional transparency requirements such as state and federal public notice and public input opportunities. The state’s application should be available shortly on the CMS 1115 Waiver webpage, and public comment may be submitted. Additionally, the state is exempted from submitting any budget neutrality requirements documenting the benefit to the federal government of the investment of the projected waiver expenses.
Without doubt, this pandemic has laid bare the critical flaws of disjointed, un-integrated health care delivery systems that exist in today’s context, sitting against the backdrop of the fee-for-service payment system. Could this waiver request build of the successful DSRIP foundational work to weave together a more comprehensive, responsive, and worthy-of-this-century health care system? All eyes are now on CMS.
How can you stay up-to-date?
Submit public comment to CMS once the application is posted, sign up for the state’s listerv to receive future updates, and talk to your peers and colleagues in your community to learn more about what’s happening in your region.
And stay in touch! Have more questions, comments, want to get into the deep dive or share your own take? You can find me on Twitter @kalinscot or by email at kalin@helgersonsolutions.com — reach out, I’d love to hear what you think.
