November 5, 2020

PCDC Testimony: Support the Integration of OMH and OASAS in New York State

Combining the New York State Office of Mental Health (OMH) and the New York State Office of Addiction Services and Supports (OASAS) into a single agency will benefit New Yorkers by providing unified behavioral health services.

The testimony identifies the importance of combining both state agencies, which would ultimately improve access especially for underserved communities to primary care and behavioral health services.

Recommendations include establishing integrated systems to share patient information, simplifying health care facility requirements, expanding financing and reimbursement options for integrated care, and ensuring bi-directional workforce education.

Primary Care Development Corporation (PCDC) submitted the following official comments to support the integration of OMH and OASAS into a unified agency.

Read the full comments from the statement below.

Primary Care Development Corporation (PCDC) Testimony on the Integration of the New York State Office of Addiction Services and Supports (OASAS) and the New York State Office of Mental Health (OMH)

October 30, 2020

Primary Care Development Corporation (PCDC) appreciates the opportunity to comment on the integration of OASAS and OMH into a single agency. PCDC is a nonprofit organization and Community Development Financial Institution (CDFI) dedicated to building equity and excellence in primary care. We provide capital financing and capacity building services throughout New York State and across the country. Our mission is to create healthier and more equitable communities by building, expanding, and strengthening the national primary care infrastructure.

PCDC’s History of Impact and Service

Since our founding in 1993, PCDC has worked with over 950 health care sites in all corners of the Empire State. PCDC provides financing for Article 28 community health and diagnostic and treatment centers, Article 31 mental health clinics, and Article 32 alcohol and substance abuse treatment clinics, in addition to technical assistance to empower providers to improve care delivery and services. In just the last five years, PCDC arranged nearly $75 million in affordable and flexible financing for community-based health care providers to support quality primary care expansion and integration across New York. As part of PCDC’s commitment to enhancing whole-person care and health outcomes, we are prioritizing projects that advance behavioral health integration and services. Our recent projects include:

  • Institute for Community Living (Kings County) – Financing support towards the construction and substantial renovation of a $29.8 million, 44,600 square foot, comprehensive service delivery hub in Brooklyn, New York, to deliver integrated primary care and behavioral health services under one roof,  including family support, outpatient programs, day treatment, and care coordination to address behavioral and physical health concerns.
  • St. Joseph’s Community Service Center (Franklin County) – A $3.3 million project to bring much needed substance use services to the rural North Country and enable the location of three important programs — a 10-bed detoxification unit, a 24/7 Open Access Center, and an expanded outpatient clinic — in one 8,000-square-foot renovated warehouse in Saranac Lake.

Nationally, we have improved primary care access by leveraging more than $1.2 billion to finance over 130 primary care projects, the majority in New York. Our strategic community investments have built the capacity to provide nearly 4 million medical visits annually, created or preserved more than 15,000 jobs in low-income communities, and transformed 1.8 million square feet of space into fully functioning primary care practices. Through our capacity building programs, PCDC has trained and coached more than 9,000 health workers to deliver superior patient-centered care. PCDC partners at federal, state, and local levels to provide far-reaching training and consultation on integrating primary care with mental health and substance use disorder services, HIV prevention and treatment, and more. We have assisted more than 800 primary care practices to achieve Patient-Centered Medical Home recognition, impacting care for more than 5 million patients nationwide. In this collective work, we hear the voices of thousands of providers and health care organizations, particularly those working to support safety net and underserved communities, and we work to represent their experiences in these critical conversations.

Support for the Integration of OMH/OASAS

As an organization dedicated to the accessibility of high-quality, comprehensive care, PCDC sees great potential in integrating two mission-aligned agencies to support New Yorkers with unified behavioral health services. Especially now – amidst an opioid epidemic and the COVID-19 pandemic – we see the compounding consequences of addiction, heightened stress, depression, anxiety and tragically, deaths of despair. We strongly believe comprehensive, quality primary care is inclusive of behavioral health treatment and prevention.

Primary care and behavioral health integration requires a shared understanding and approach to behavioral health. Organizations striving to provide integrated care are hindered by the regulatory complexities that arise from the siloed nature of New York’s various health service offices. PCDC views the proposed integration of OASAS and OMH as fundamental and an opportunity to enhance the way mental health and substance use services, and ultimately primary care services broadly are delivered. Integrating the regulation and leadership of substance use and mental health services is necessary as we move increasingly towards the bi-directional integration of primary care and behavioral health.

The Importance of Primary Care and Behavioral Health Integration

Nationally, one in five people have a mental illness and five percent of the total population have a Serious Mental Illness (SMI). Individuals with SMI often experience high rates of acute and chronic medical conditions, and adults with SMI have substantially reduced life expectancy, often due to treatable medical conditions. In conjunction with diminished health status, these individuals also experience a 60 to 75% higher cost of care than individuals without a mental health illness.

Although primary care providers are increasingly screening for and treating common behavioral health conditions such as depression and anxiety, they only reach a fraction of those in need. Meanwhile, those living with SMI, who are often seen in behavioral health settings, generally lack adequate primary care access. The need for affordable, accessible, and evidence-based treatments for behavioral health conditions remains high, and it has become increasingly clear that the separation of physical and mental health prevention and treatment is not yielding improved health outcomes.

One of the most effective ways to address the evident need to improve outcomes and reduce costs in the current delivery system is integrating behavioral health and primary care for patients with mental and physical comorbidities. While several integration models exist, PCDC is of the firm belief that integration must be bi-directional: integrating primary care services into a behavioral health setting or behavioral health services into a primary care setting. While the call to integrate behavioral health and primary care to serve patients better has resonated widely, there are still significant barriers to successful, widespread implementation.

Impact on Equity and Access to Care

Behavioral health conditions – both mental health and substance use disorders – can lead to and amplify disparities in access and quality of health care, especially for racial and ethnic minorities, individuals of lower socioeconomic status, rural residents, LGBTQIA+ individuals, and individuals with limited English proficiency. The barriers experienced by these groups and others are often associated with the inability to access both behavioral health and primary care providers in a single facility or the lack of coordinated communication and data sharing between providers. PCDC’s research found some major barriers to improving and expanding integrated care services in New York centered on burdensome regulatory requirements surrounding facilities and reimbursement.

The State should move quickly to fully modernize physical plant requirements, satellite clinics, telemedicine regulations, and those governing the integration of physical and behavioral health across offices, including the DOH, OMH, OASAS, and OPWDD. The COVID-19 pandemic has shown that the federal and state governments can move quickly to waive existing regulatory requirements that can serve as operational barriers – as has been done with telehealth. Primary care access in poor and minority communities has been hampered by the byzantine regulatory framework of New York’s licensure system and reimbursement practices. Now is the time to move swiftly and decisively to meet the needs of New Yorkers and heighten the bi-directional integration of primary care and behavioral health.

PCDC is proud to have been a main lender for several integrated facility projects and both local and national training and consulting to advance integrated care. PCDC believes that the health care system should treat patients as whole people, deserving of person-centered care in a comfortable, accessible, and equitable environment. Integrating behavioral health services along with primary care is increasingly recognized as a critical component of whole-person care and improved health outcomes and the integration of these two agencies is an opportunity to move towards fulfilling this potential.


  • Establish integrated systems to share patient information: The merger of OMH and OASAS provides a prime opportunity for increased information sharing and for a reduction in duplicated systems found across funding streams and payer types. This merger will also allow OMH/OASAS to develop their own mechanism for sharing information that is highly effective and patient centered. Including primary care facilities in this structure will allow for an increase in information sharing at the point of care and much-needed population health management.
  • Simplify health care facility requirements: New York has distinct facility licenses and building requirements for providers and health centers to receive Medicaid reimbursement which do not exist in many other states. Regulatory and licensing requirements are complex and burdensome for providers, often deterring expansion of facilities to implement behavioral health integration. We urge the State to simplify these requirements to reduce these detrimental barriers.
  • Expanding financing and reimbursement options for integrated care: Both behavioral and primary care facilities have historically been underfunded. It is essential that the newly integrated agency provides the funding and reimbursement support to enable providers to adopt integrated care models. Many of these facilities are heavily reliant on grant funding, and while grants are an important component of health care funding, they are not sustainable. Additionally, current Medicaid billing structures do not allow reimbursement of core integrated care services, which is a hinderance to expanding behavioral health integration.
  • Ensure bi-directional workforce education: With the consolidation of these agencies and the integration of primary care into this framework, providers and staff will need additional training and support to effectively work in integrated health care facilities and adequately meet the needs of their patient populations. This will ensure that primary care staff is familiar with managing behavioral health conditions and the impact of trauma on clinical outcomes, while behavioral health providers gain knowledge of chronic medical conditions and behavioral interventions that can improve clinical outcomes. Bi-directional education helps to create a shared vision and culture for integrated service providers.

Thank you for your consideration of these recommendations. Primary care is the foundation of the health care system and a cornerstone of healthy, thriving communities. The merger of OMH and OASAS should be the catalyst to focus on integrated primary and behavioral health care in New York and affect meaningful change on the path to achieving health equity for all communities.


Primary Care Development Corporation (PCDC)
Cynthia SummersManaging Director of Strategy and Public Affairs
(212) 437-3933 |