Comments on NYSDOH Draft Primary Care Medicaid Standards

PCDC, 2008

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We applaud the leadership of the NYS Department of Health in proposing new quality standards for providers of primary care under the Medicaid program and are pleased to have the opportunity to comment on them. In providing these comments, Primary Care Development Corporation draws on its considerable experience helping primary care providers in varied settings assure continuity, organize strong primary care teams, reduce wait times, shorten total visit length, increase provider capacity, adopt electronic health records, prepare for emergencies, and build financially strong operations.

These standards reflect a growing consensus in the medical community regarding the elements of primary care essential to improving health outcomes, reducing disparities and addressing soaring health care costs. They align closely with the Institute of Medicine definition of patient-centeredness, the Wagner planned care model and the NCQA Patient-Centered Medical Home standards that are being incorporated into demonstration projects around the country.

A large gap exists, however, between the proposed standards and the current practice of primary care, which is still largely episodic, poorly coordinated, and unsuited to addressing patient needs. It is important to recognize that many, if not most, providers are not close to meeting them and that implementing these standards in a way that does not disrupt care will require education, a well-considered timeframe and implementation plan, and the assurance that providers have the necessary resources.

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