New York State

Define, measure, report and increase the proportion of New York’s health care dollar allocated to primary care.

New York’s underserved communities have a pressing need for primary care, yet the providers and institutions that serve them have been unable to sufficiently sustain, expand, and improve services due to systemic underfunding and undervaluing of primary care services. New York’s health care costs per resident are the second highest in the country. However, this massive investment has not paid off in outcomes. Despite its high spending, New York does not rank among the top 10 states for many health indicators. It is in this context that PCDC believes that New York should work to realign our health care system through a deliberate strategy to define, measure, report on, and increase the proportion of the health care dollar allocated to primary care.

Preserve the 340B Drug Pricing Program to protect medically underserved communities.

The NYS enacted budget for SFY 2020-21 includes a recommendation made by the New York State Medicaid Redesign Team II in March of 2020 to transition, or “carve out,” the Medicaid pharmacy benefit from Managed Care to Fee for Service (FFS), beginning April 1, 2021 which could effectively end the savings received through the 340B program and ultimately limit services and access for New York’s low-income, vulnerable communities. The 340B Program entitles qualifying entities — Health Resources and Services Administration (HRSA)-supported health centers, AIDS drug assistance programs, and safety net hospitals and providers — to receive discounts on eligible outpatient drugs. Covered entities may provide 340B drugs to all eligible patients, regardless of a patient’s payer status or how the drug is administered. PCDC is gravely concerned about the downstream effects of limiting the 340B program and strongly supports rescinding this proposed policy.

The 340B discounts allow community health centers, critical access hospitals, and other safety net health providers to obtain life-saving medicine at a reduced cost. With the shift of the pharmacy benefit from managed care to FFS, invaluable funds are removed from the providers and the community where they would be most impactful. The Community Health Care Association of New York State (CHCANYS) has stated this change will result in a loss of $100M in unrestricted revenue for direct service delivery a year for FQHCs. Because 340B providers exclusively see the most vulnerable populations, limiting the program will disproportionally impact these already hard-hit communities. While a complete rejection of any pharmacy “carve out” would be the best result for our neediest communities, we support Senate bill 8948 and Assembly bill 10960 and the efforts to delay implementation as a means of safeguarding the sustainability of safety net providers and the populations they serve.

For more information, check out the 340B and Health Care Facility Financing: The Role of 340B in Safety Net Providers’ Financial Stability fact sheet.

Protect funding for Patient-Centered Medical Homes (PCMH) incentive programs.

The PCMH model relies on primary care physicians to coordinate care for their patients in an appropriate manner where and when they need it. PCMH puts patients at the forefront of their care delivery. Research shows that PCMHs build better relationships between patients and their care teams; improve quality, patient experience, and staff satisfaction; and reduce health care costs.

PCMH has been central to health care payment reform in New York’s Medicaid program. Primary care providers across the state have responded to the State’s reform efforts by becoming PCMH certified at unprecedented rates — New York State currently has the highest percentage of PCMH certified providers in the country.

Given the demonstrated benefits the PCMH program has and will continue to produce, PCDC has persistently advocated for renewed and increased funding for New York’s PCMH program and supported policies that will expand the model’s reach and impact.

Primary care must be a central priority in delivery and payment system transformation efforts.

PCDC supports efforts made by New York State to transform the health care system, including using 1115 Medicaid Waivers to implement initiatives such as DSRIP. However, the desired transformation can only be accomplished with sufficient, quality primary care that is accessible to all families and communities. The need for increased investment and more effective policies to achieve the promise of primary care is clear. PCDC has advocated in several forums for New York State to enhance primary care within system transformation.

Increase access to care in New York State in order to improve health status. 

PCDC has identified significant correlations — between primary care access and overall health status; higher poverty rates and worse health outcomes; and rural counties and a lack of primary care access — based on defined measures of access and need. To mitigate these findings, the State must ensure a sufficient number of primary care providers in every county, work toward primary care access parity for people living in rural communities, and encourage capital access and reimbursement models that reward proven quality programs.

Enhance community development through strategic capital financing. 

The Community Health Care Revolving Capital Fund is a financing program created in January 2017 through a public-private partnership between PCDC and the State of New York, with generous funding from the state. Administered by PCDC in partnership with DOH and DASNY, the revolving fund provides affordable and flexible loans to Article 28 health centers, Article 31 mental health centers, and Article 32 substance use disorder treatment centers to finance the construction, expansion, and renovation of community health care facilities throughout New York State. Examples of successful projects financed by PCDC through the revolving fund include Callen-Lorde’s Brooklyn expansion and St. Joseph’s Community Service Center. PCDC is committed to using this and other funding streams to make meaningful, flexible loans to New York providers who need it.

Streamline integrated facility requirements and create financial incentives for integrated care reimbursement models.

New York is one of many states that has distinct facility licenses and building requirements for providers and health centers to receive Medicaid reimbursement. PCDC found several barriers to the current state approaches intended to reduce the complexity of these requirements, including limited uptake of the DSRIP integrated care license, utilization thresholds that do not meet the needs of larger health centers and practices, service/billing limitations, and difficult administrative requirements. PCDC urges the state to simplify these licensing requirements in order to reduce these detrimental barriers.

Additionally, regulatory guidelines prohibit billing for a behavioral visit on the same day as a primary care visit when providers use the same provider number. Furthermore, current Medicaid and Medicare billing structures do not allow for reimbursing core integrated care services such as provider consultation time and care team meetings, and value-based payment does not yet fully cover these and other integration costs. Delivery system payment reform must meaningfully adhere to the needs of integrated care models.