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Housing Works’ Comments on the Proposals Submitted to and Adopted by the Medicaid Redesign

Team on February 24, 2011.


(In addition, Housing Works has one NEW proposal for submission based on action taken yesterday
by the Federal Government.)

Associated page numbers are from the 2011-02-24_staff_draft_proposals_with_descriptions.pdf


PROPO PAGE PROPOSAL DESCRIPTION HOUSING WORKS’ COMMENTS
SAL NUMB
NUMBE ER
R
#10 9 Eliminate Direct Marketing of Special Needs Plans should be exempted. A high percentage
Medicaid Recipients by of people with HIV do not understand the benefits of a SNP
Medicaid Managed Care Plans option or do not know that they are HIV positive when they
choose a managed care plan and therefore have no reason to
consider a snp. Moreover, SNP’s cannot participate in auto-
assignment. It is inconsistent to say that people with HIV can
opt out of a mainstream plan for a SNP at any point but not
give the SNP’s the ability to market their services. Also, if the
goal is to expand to snps to include other currently non-
mandated populations for medical home, the SNPS would have
to be able to market to these populations.
#11 11 Bundle Pharmacy into MMC The rate for this benefit would have to be separately
calculated for SNP’s unless HIV medications remain carved out.
Otherwise this will have a very bad impact on SNP viability.
Moreover, any capitation should take into account the fact that
the only generic AV’s are older drugs that are less effective
and have greater side effects. It should also take into account
increasing evidence that earlier initiation of ARV’s, including
immediately upon HIV infection, has significant health benefits
as well as a strong prevention effect. Any effort to calculate
this benefit based on disease progression would be counter-
productive.
#15 18 Consolidate all pharmacy fee- It is not clear if this proposal would bring ARV’s and other AIDS

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for-service proposals into a medications into the PDL. While Housing Works, alone among
comprehensive reform AIDS organizations has supported this in the past, we strongly
package. oppose folding in HIV/AIDS medications into the PDL without a
“provider prevails” provision. Also, we strongly oppose prior
authorization for ARV’s. It is not clear what the benefit of prior
authorization is for ARV’s and what reason there would be to
decline authorization. If the state’s current standards, which
are out of sync with the Federal standard, were used, this
could deprive people from seeking early treatment and be a
disincentive to early testing. Any pre-authorization
requirement would have a negative impact on use of ARV’s for
either pre- or post-exposure prophylaxis.
Attachm 42 Limit opioids to a four While this proposal is probably manageable, initiation of pain
ent prescription fill limit every management, particularly for chronic pain, may require
#15K thirty days. frequent dose adjustments and /or changes in drugs or drug
combinations. The first 30 days of therapy may require more
frequent prescriptions for opioids. This should be taken into
account in developing by-pass provisions.
#17 47 Reduce fee-for-service dental Housing Works opposes this proposal as it will limit dental
payment on select procedures access for Medicaid recipients, particularly in places where no
dental clinics exists or where art. 28 clinics are oversubscribed.
#18 49 Eliminate spousal refusal. This proposal may have the unintended consequence of
driving up the cost of the AIDS drug assistance program if
spouses or parents cannot afford the cost of HIV/AIDS
medications or may result in people living with HIV not
receiving care.
#24 54 Payment for Enteral Formula Housing Works opposes this proposal as it will have a
with Medical Necessity Criteria negative impact on people with advanced HIV or AIDS,
especially those with concurrent conditions such as renal
failure and cancer. Many of these people are not capable of
preparing or may not have the resources to purchase foods
necessary for a special diet. Requiring persons to be
underweight to receive this benefit would negatively impact
health outcomes for these people.
#37 70 Eliminate Case Mix Adj for AIDS Housing Works supports this proposal. As an alternative, the
Nursing Svcs in CHHA and assessment tool should capture behavioral health needs that
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LTHHCP Programs might make home health care more expensive, requiring
better-trained workers or more hours of care. (See comment
on #69)
#41 72 Establish the Public Health Housing Works supports this proposal. However, incentives
Services Corps for persons trained in HIV and/or community medicine must be
a part of this proposal and have not been included in the
proposal as written. Professionals often avoid certain disease
classes, including HIV and addiction, and often avoid classes of
people including those who are homeless and active drug
users.
#49 76 Reimburse Art 28 clinics for HIV Housing Works supports this proposal. These rates maintain
counseling/testing using APGs the ability to bill for a counseling-only visit for someone who
elects not to take an HIV test. The test HIV is still billed
separately from other billing if there is an additional clinical
matter. Rapid testing has been included and has been
expanded to allow billing by all providers. While this proposal
will result in a slight decrease in payments per test, it has the
potential to dramatically increase the number of people who
receive counseling and who receive testing.
#55 80 Increase coverage of tobacco Housing Works supports this proposal.
cessation counseling
#69 92 Develop and Implement a While Housing Works supports this proposal, we are
Uniform Assessment Tool (UAT) concerned that this assessment adequately account for the
for LTC varying needs of people living with HIV and other chronic
conditions such as mental illness, chronic chemical
dependence, and homelessness. We propose that HIV service
providers, such as AIDS Adult Day Health Care, be included in
the development of this assessment tool and participate in
beta testing and piloting it.
#83 101 Expand SBIRT for alcohol/drug Housing Works supports this proposal.
to hospital clinic, DTC and
office settings.
#89 103 Implement Health Home for Housing Works supports this proposal.
High-Cost, High-Need Enrollees
#93 110 Establish behavioral health This proposal should be rewritten to allow a variety of
organizations to manage demonstration models for managing behavioral health.
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carved-out behavioral health Reliance a single BHO for each region will likely negatively
services impact the ability to develop new models of integrated care,
including the development of new co-location and other PACE-
like models.

#101 114 Develop Initiatives to Integrate Housing Works supports this proposal and recommends that
and Manage Care for Dual the SNP’s be incorporated into this planning and that PACE-like
Eligibles models be a key component for people with multiple chronic
conditions.

#104 121 Increase Enrollee Copayment Housing Works opposes this proposal. Where providers follow
Amounts for Medicaid Fee-for- the law and don’t require payment for patients who cannot
Service and Family Health Plus; afford the co-pay, this is simply a reduction in rates in disguise.
Require Where providers attempt to collect, the co-pays are a barrier
Copayments for Child Health to basic and necessary care that, if not provided, will lead to
Plus more expensive treatment.

#109 125 Require Hospitals and Nursing Housing Works supports this proposal.
Homes to provide Patient
Centered Palliative Care
#131 134 Reform Medical Malpractice Housing Works supports malpractice reform that focuses on
and Patient Safety improvement of patient safety. It is not clear that this
proposal as written, will accomplish this since at least initially
the savings come through caps in damages as opposed to
changing clinical practice.

#150 156 Develop an Automated Housing Works supports this proposal.


Exchange/Medicaid Eligibility
System
#153 159 Develop innovative Housing Works supports this proposal.
telemedicine applications by
reducing regulatory barriers
and providing payment
incentives
#196 169 Supportive Housing Initiative Housing Works supports this proposal but urges that the
initiative consider the full range of populations with chronic
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conditions in need of supportive housing, not just to avert
nursing home stays but to ensure medical and psychosocial
stability and adherence to treatment as well as prevention of
disease transmission. There is clearly documented evidence
particularly with people with HIV, but also with other homeless
and chronically ill populations that housing is a cost-effective
intervention that achieves treatment adherence and
significantly reduces costs while improving health outcomes.
There is compelling evidence that housing of people who are
HIV positive and those at highest risk dramatically reduces
transmission of HIV as well.
#209 173 Expand Hospice Housing Works supports this proposal.
#217 175 Create an office for Housing Works supports this proposal.
development of patient-
centered primary care
initiatives
#243 177 Explore Models to Implement Housing Works has concerns about the role of community
Accountable Care based providers and other community-based groups of
Organizations (ACOs) providers in the ACO scheme, including their ability to operate
or have a significant voice in the operation of ACO’s rather
than functioning as a subsidiary partner to a hospital or
network of hospitals.

#990 186 Explore the Establishment of Housing Works supports this proposal.
Reimbursement Rates to
Support Efforts to Address
Health Disparities
#1021 188 Facilitating Co-Located physical Housing Works supports this proposal.
health, behavioral health and
developmental disability
services
#1029 190 Enrollment and Retention Housing Works supports this proposal.
Simplification
#1058 195 Maximize Peer Services Housing Works supports this proposal.
#1451 206 Establish various MRT Housing Works supports this proposal.
workgroups
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#1458 208 Care Management Population Housing Works has concerns that people will be mandated into
and Benefit Expansion, Access managed care without a clear understanding of their rights
to Services, and Consumer and without the services available. Already, thousands of
Rights homeless New Yorkers, for example, are enrolled and even
auto-assigned to a plan with even knowing their right to
disenroll. Mainstream plans rarely provide them the services
they need, apparently willing to accept the ultimately higher
costs of care as a “cost of doing business” without regard for
the negative health outcomes. The State needs to establish
upfront the essential elements any plan must have in place to
identify and meet the needs of these discrete populations,
including, where appropriate, special needs plans. And the
state must ensure that there are sufficient plans who meet
those requirements before it mandates managed care
enrollment. For example, it would be wholly inappropriate to
mandate enrollment of people with HIV in managed care in
parts of the state where this would exacerbate a lack of choice
in providers or where there are no HIV/AIDS special needs
plans.
#1458 216 Streamline Managed Care Housing Works supports this proposal in principle but has
Attachm Enrollment Eligibility Process concerns about the education new enrollees will receive,
ent 3 particularly in light of the elimination of managed care plan
marketing funds, to understand their options, including the
option to opt for a special needs plan or to opt out of managed
care altogether if they meet the criteria to do so.

#4647 223 Expand Managed Addiction Housing Works would support this proposal if Harm Reduction
Treatment Program (MATS) approaches to addiction treatment were incorporated into it.
(See Housing Works’ new proposal below.) Further,
Housing Works has concerns about how MATS would integrate
with other Health Homes for patients it enrolls.

#4648 226 Family Planning Benefit Housing Works supports this proposal.
Program as a State Plan
Service
#4651 229 Global Spending Cap on Housing Works supports the development of a two-year budget
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Medicaid Expenditures for Medicaid. However, we have strong concerns with the rest
of this proposal because of the authority it gives DOH to
unilaterally cut funding for services during the budget period
as well as the fluctuations that enrollment can generate
against such a global cap. As it is, the proposed 2% across the
board reduction unfairly hits programs that have not seen rate
increases in years as well as programs that have had the
benefit of year after year trend factors. This wholesale
approach to cost reduction gives little reason to believe that
future unilateral cuts will be any more fairly allocated or any
less subject to the influence of New York’s health care power
brokers than they have been in the past.
NEW PROPOSAL Active drug users are often out of care due to behavior
and practice associated with their chaotic life style.
They are heavy users of emergency room and impatient
care. The Federal government just certified needle
exchange as a “drug treatment”. The state should
explore using Medicaid to reimburse needle exchange
and harm reduction therapy. These interventions are
proven to reduce HIV and Hep C transmission. In
addition, they dramatically reduce drug overdose and
frequently serve as a gateway into abstinence therapy
and into coordinated health care.

Charles King, President and CEO


Housing Works, Inc.
57 Willoughby Street, 2nd Floor
Brooklyn, NY 11201
347-473-7401
king@housingworks.org
www.housingworks.org

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