New York Health Equity Reform (NYHER)
1115 Waiver Amendment Request FAQ
- FAQs also available in Portable Document Format (PDF)
The following summarizes and addresses questions as part of the public comments received by the New York State (NYS) Department of Health (DOH) in response to the NYHER 1115 Waiver Amendment Application, as part of the public comment process.
Housing
Q: The draft waiver amendment application used the terminology "psupportive housing,"p but will the State consider using "ptransitional housing"p to better describe the housing and services proposed in Strategy #2?
A: NYS agrees with this suggestion, and we have clarified in the final application that Strategy #2 provisions provide transitional housing services.
Q: Will NYS include older adults in the housing section of the waiver amendment?
A: The waiver amendment already includes older adults who are living in institutional settings, such as nursing homes and long-term care facilities.
Q: Will NYS increase investments under the housing-related strategy?
A: No. The waiver amendment application represents a $1.57 billion investment in transitional housing for high needs Medicaid enrollees over five years.
Q: Are pre-housing services included in the housing provisions?
A: Yes, we have clarified in the final application that transition services include services to prepare an individual for housing and connections to health care services.
Q: Will NYS expand the number of funded housing opportunities for homeless populations with medical, behavioral health, and social care needs?
A: The Enhanced Transitional Housing Initiative will include services to help individuals stay safely housed in the community and connection to housing for individuals experiencing homelessness, including those with medical, behavioral health, and social care needs, and individuals leaving long term institutional settings. Creating new housing is beyond the scope of this waiver amendment.
Workforce
Q: Will NYS include investments in community health workers, to address the behavioral health workforce shortage, or to address critical workforce shortage areas? Will NYS include investments in human services and/or CBO staff in the waiver amendment to enable participation in VBP and waiver initiatives?
A: NYS recognizes the critical workforce shortages across all sectors of the healthcare system, which is why we have tried to create proposal that investments across the healthcare continuum. Community health workers are an important part of the workforce and key to advancing health equity, which is why we have included them in the workforce investments. We also recognize that there is shortage in the behavioral health workforce and have clarified their inclusion in recruitment and retention initiatives. The capacity building and training initiatives outlined in Strategy #1.2 and #1.4 include training investments in CBO staff to support participation in VBP and waiver initiatives, and investments in Strategy #3 to address workforce shortages and support the expansion of community health workers, care navigators and peer support workers.
Q: Will NYS use the Area Health Education Center (AHEC) system in addition to WIOs?
A: NYS anticipates that Workforce Investment Organizations (WIOs) will partner with other workforce development centers operated at the local and regional level.
Telehealth
Q: Will NYS include payment parity for telehealth services and/or account for a lack of broadband access for some Medicaid enrollees?
A: Payment parity for telehealth services affirms that the high-quality care provided at in-person visits is also achieved when the same service is offered via telehealth. The NYS 2023 Enacted Budget (Health and Mental Hygiene, Part V) included a provision for telehealth parity, which requires payers to reimburse telehealth services "pon the same basis, at the same rate, and to the same extent"p as services delivered in person. Certain fees (e.g., facilities fees) are excluded from this requirement when such costs are not incurred (e.g., when patient and provider are both off-site). NYS is creating additional billing guidance to address clinic telehealth billing.
Several of the initiatives under Strategy #4 of the waiver amendment application aim to bring digital health options to rural communities and other parts of the state that lack broadband access. Community health workers will be outfitted with telehealth backpacks that include the technology necessary to boost internet connectivity as well as devices needed to connect patients to healthcare providers. Additionally, NYS will furnish tablets with data plans to providers and Medicaid enrollees in areas identified as high need, including broadband deserts.
Q: Will NYS use telehealth funding to increase access to services for the I/DD population?
A: Many of the telehealth initiatives in the waiver amendment application are intended to bring care to those with I/DD and/or physical disabilities. Specialty virtual care models will be expressly designed to serve people who face accessibility barriers, such as people with long term care needs and/or people with I/DD. Funding will be used to connect homebound enrollees and those living in residential facilities with equipment and virtual care subscriptions. Collaboration with the I/DD field will be essential in designing programs and policies that meet the unique needs of the population.
Q: Will NYS unify communication and coordination of physical, behavioral, and social care across the care continuum?
A: Telehealth can be used broadly in both addressing patient’s physical, behavioral, and social care needs, and in creating digital provider networks to coordinate care for their patients. NYS intends to use digital infrastructure to identify patients that would benefit from care coordination and other supports, such as health homes. A statewide collaborative group will identify strategies for building and supporting needed digital infrastructure.
Q: How will the telehealth platform leverage proven best practices, established technology as well as breakthrough innovations?
A: The statewide collaborative will identify strategies for building and supporting needed digital infrastructure. We envision the collaborative will include experts and stakeholders representing different populations and geographies and will contribute their knowledge around best practices and innovations.
Health Equity Definition and Special Populations
Q: Will NYS define health equity in the waiver amendment?
A: In the final application we have included the definition of health equity from the Robert Wood Johnson Foundation in the introduction.
Q: Will NYS prioritize people with I/DD or dual eligibles in the waiver amendment?
A: We have clarified in several section of the waiver where I/DD populations fit in, including as a targeted population that HEROs may focus on based on regional priorities. While not specifically named in the waiver document, NYS considers duals/older adults to be represented throughout, including in the HERO strategies in Strategy #1.1 where "providers of long-term services and supports (LTSS)" are named, in Strategy #2 "Investing in Transitional Housing Services and Alternatives for the Homeless and Long-Term Institutional Populations" whereby it will "ensure the availability of sufficient long-term services and supports and accessible health care capacity to enable aging in place," and in Strategy #3 to strengthen the workforce for LTSS.
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