Starting the Clock: New York Medicaid Program Releases Draft of $13.52 Billion Waiver Request
Post Written by Kalin Scott, Chief Innovation Officer
On April 13, 2022, New York Medicaid released its formal request to the federal government for a $13.52 billion investment in continued delivery system reform. The request reinforced the state’s total commitment to payment reform: $7 billion dollars - more than 52% of the requested funding - would be invested in advancing value-based payment (VBP) models in Medicaid.
This long-awaited draft 1115 Medicaid waiver amendment is the follow-up to the state’s successful Delivery System Reform Incentive Payment (DSRIP) program. The state outlines a detailed request for five years of funding, totaling $13.52 billion which would fund providers and communities through Medicaid to promote health equity, address the social care needs of Medicaid members, build on the success of DSRIP, and expand advanced models of VBP.
We last saw the state’s official position on this approach in August 2021 with the release of a very similar concept paper outlining a proposed investment of $17B and proposed strategies to accomplish many of these same goals.
What does this all mean?
The shorter answer: New York has followed through on its commitment to approach CMS with a request for significant investment in its Medicaid program. The release of this draft triggers a waiver approval timeline and signals that New York will formally submit this amendment request in as soon as thirty days (by mid-May.) The state has also added more financial details and timelines to their approach - and signaled its desire to have this amendment and related programs in place by January 1, 2023.
The state Medicaid program is clearly fully committed to VBP and reflects that in the $7B commitment to supporting advanced VBP models. The VBP Roadmap - which outlines the requirements for plans and providers - will continue to be one of the most important documents in the state’s $92B Medicaid program. Along with this focus on VBP, proposed investments in supportive housing, services for criminal justice-involved populations, health equity, social care needs, workforce training, and telehealth all outline key areas of focus for New York Medicaid strategic priorities.
What does this mean for providers, plans or other key health care stakeholders? If you’re going to continue in or enter the New York Medicaid market, you need to have a VBP strategy - this document makes that absolutely clear. Building relationships with other health and social care providers, managed care organizations, and key stakeholders should also be a focus for anyone who wants to be involved in this effort in the future.
How much of the state’s August 2021 concept paper is reflected in this document?
The waiver amendment draft is very similar to what the state released in August 2021, so if you’re familiar with that, you know the major elements. If you haven’t yet reviewed that release, I’ve got you covered – my summary of the key components will give you what you need to know.
What’s new? What’s changed since August 2021?
Most significantly, more financial details have been released, signaling the state’s policy priorities. The overall dollar value of the request to CMS has decreased – in August 2021, the state outlined a $17B request, and this updated document reduces the number by about 20% to $13.52B. In addition, this April 2022 release outlines specific investment targets for each goal and program in the proposed waiver programs.
Most notably, more than half of all requested funds - $7B – will be used to drive further adoption of advanced VBP models throughout the state’s Medicaid program.
Medicaid officials had mentioned in the past that CMS had previously pushed back on the initial dollar figure – this update reflects that feedback. This document also reflects alignment with the key strategic priorities CMS has outlined in recent updates on the federal government's strategic priorities for Medicaid and the Center for Medicare and Medicaid Innovation (CMMI.)
In addition to the significant budget for VBP, there is more than $1.5B committed to supportive housing initiatives – which would be the largest investment by any state Medicaid program to date. New York has led the nation on innovative strategies and investments (more than $800M of state-only Medicaid dollars since 2011) in supportive housing for Medicaid members, and has seen significant return on investment and improved member outcomes as a result of that work. This expanded partnership with the federal government would be a major first.
Are there additional details on funding opportunities for Medicaid providers and stakeholders?
The state proposes a January 1, 2023 starting date for the programs outlined in this request, and anticipates that $928M in spending would take place in the first year.
$910M over the five-year period would flow to yet-to-be-created Health Equity Regional Organizations (HEROs) and Social Determinants of Health Networks (SDHNs.) These entities were outlined in the August 2021 concept paper – this document is consistent with the previous descriptions, along with a caveat that their work would be ramped up over the course of the five-year period. Funding would not go out the door immediately – the state would likely take the time to allow for a selection process, the details of which have not yet been released.
Need more background on what this is all about?
New York’s DSRIP program, launched in 2014, was the foundation of the work outlined in this ask, and launched the state’s path to VBP. Check out this post for more context on DSRIP and how it relates to future efforts in New York Medicaid.
Here’s how to comment and stay involved
While releasing this draft waiver amendment is a huge milestone for New York, the program itself is far from a done deal. There is no guarantee CMS will approve this request or any future investment. If there is interest from the CMS team, the state will enter into an intensely detailed negotiations process, and what’s reflected in this document is very likely to change significantly.
The state is required to follow a thorough public transparency process, which was triggered with the release of this document. This kicks off a public comment period – stakeholders with any interest in or connection to Medicaid in New York should make a plan to get involved and provide comment.
New York’s Medicaid team has historically had a strong track record of reflecting public comment and stakeholder feedback in its waiver documents, and CMS will also be ensuring the state has considered all feedback.
The state posted the details of its public comment period on its website. The first opportunity will take place on April 28. The state also has a listserv for announcements related to the Medicaid program and 1115 Waiver – you’ll want to sign up for that to make sure you get the latest updates.
More to Come
What questions or reactions do you have to the state’s approach? What parts of the waiver amendment would you like to see our take on? Share your questions and thoughts through the contact info below – I’d be happy to hear from you. And stay tuned – more to come on what this means for providers and stakeholders in New York and beyond.
About the Author: Kalin Scott is the Chief Innovation Officer at Helgerson Solutions Group. Follow her on Twitter and connect with her on LinkedIn.
