New York State Releases New Value-Based Payment Roadmap
Post Written by Kalin Scott, Chief Innovation Officer
Part 1: Brief Overview & How to Weigh In
On January 19, 2022, the New York State Department of Health released an updated draft Value Based Payment Roadmap for a 30-day public comment, running through February 18, 2022. The public comment period will run through February 18. The document will be updated after that process and submitted to CMS for approval.
The major takeaway here – this release is another significant sign from New York’s Medicaid program that value based payment (VBP) remains a top priority for Medicaid. This is the first update of the document since the end of the state’s Delivery System Reform Incentive Payment (DSRIP) program, and reflects the state’s commitment to VBP as a central focus of the Medicaid program.
Ambitious goals have been met since the inception of the first VBP Roadmap: In 2015, the state committed to make 80% of all Medicaid managed care payments value based by 2020, and to further ensure that at least 35% would be in advanced risk-sharing agreements. The commitment and partnership between state Medicaid, MCOs, and providers ensured these goals were met by 2020.
VBP will be a major focus of New York Medicaid policy in the coming years: in the Executive Summary, the state indicates that the public comment process will support the collection of feedback for a ‘forthcoming, more substantive update’ to the VBP roadmap aligned with the state’s next 1115 waiver program (outlined in the state’s August 2021 concept paper) intended to address health disparities and continue and expand delivery system and payment reforms built through DSRIP.
For the most part, the Roadmap remains the same: the state suggests that this document ‘condenses and clarifies the previous and does not contain any material changes to the requirements of the program.’ The revisions and updates are explained as an effort to modernize and clean up the document, and take the VBP Roadmap from a 90+ page document to a 23 page streamlined version.
Still, some notable changes are reflected, such as an update to the CBO requirement: a previous requirement to engage Tier 1 community-based organizations (CBOs) – CBOs that are non-profit and non-Medicaid billing – in advanced VBP arrangements has been revised. These advanced agreements must still include a CBO – but there is no requirement that the CBO not be Medicaid -billing, allowing for many more organizations to qualify.
MLTC Partial Capitation VBP requirements move from mandatory to voluntary: the previous Roadmap outlined standards for MLTC partial cap plans to meet related to Level 1 and Level 2 arrangements. The newly updated version removes the requirement, and makes participation in VBP arrangements for these plans voluntary.
Integrated Primary Care (IPC) references have been removed: a previous focus on IPC arrangements was a key component of previous versions. These references have been removed as DOH reviewed existing arrangements and recognized that standard IPC definitions were not in use. The state is examining how best to support chronic care and primary care bundles going forward, but is suspending data and analytics support for these models at the moment.
Data & Analytics Tools Still a Vested Interest: DOH reaffirms its commitment to making data more accessible to MCOs and VBP contractors, and underscores the value of the Medicaid Analytics and Performance Portal (MAPP) Version 2 to support VBP arrangements. Additionally, DOH signals the future release of public-facing dashboards for additional information on cost and quality performance in Medicaid.
About the VBP Roadmap
New York has had a CMS-approved VBP Roadmap in place since July 2015. As part of the state’s MRT Waiver Amendment, approved in 2014, CMS required the state to develop a multi-year roadmap for comprehensive payment reform to sustain investments made through DSRIP. Since that time, CMS has released a roadmap for all states, underscoring the need for acceleration of the adoption of VBP arrangements across Medicaid populations.
The VBP Roadmap is the governing document outlining requirements and expectations for Medicaid Managed Care Organizations (MCOs) and VBP contractors aligned with the state’s commitment to VBP. The VBP roadmap outlines standards and guidelines. Standards translate into requirements for Medicaid MCOs and VBP contractors, reflected in the state’s Medicaid model contract for MCOs and contract approval documents for MCOs/providers. Guidelines are essentially recommended best practices for MCOs and VBP contractors, but are not required.
The current CMS-approved version of the VBP Roadmap was finalized in September 2019 and approved by CMS in January 2020.
In 2015, New York launched an extensive stakeholder engagement process to develop the VBP roadmap, tapping into health care stakeholders, other state agencies, consumer advocates and clinical experts. The report has been updated annually per CMS requirements. While the DSRIP program ended in 2020, New York has remained committed to maintaining and expanding VBP arrangements in the Medicaid program.
A recent concept paper – envisioned to be the follow-up to DSRIP to further delivery system reform and promote health equity – centers around expanding VBP models throughout the state. This updated VBP roadmap is the bridge between the DSRIP program and the next opportunity for Medicaid MCOs and providers in the state to advance VBP models for Medicaid members.
Have Something to Weigh in On? Share Your Feedback Directly with DOH
The state is collecting feedback through February 18, and will host a webinar overview and Q&A session on January 25 at 1 PM EST – you can register here. Additionally, stakeholder feedback can be submitted to the state’s VBP team via email, and a spreadsheet template is the state’s preferred method of collecting feedback. More details are included in the state’s public notice.
What Else to Watch For
After the public comment period closes on February 18, this document will be finalized, and DOH will send the updated document to CMS for approval. Previous approvals have been straightforward – CMS has typically taken the state’s proposed changes and approved them as-is.
Alongside this process, the state is preparing to submit a waiver amendment to CMS outlining its proposal to continue delivery system reform and payment system reform, and outlined in an August 2021 concept paper describing a potential $17B program focused on reducing health disparities and promoting health equity.
Governor Kathy Hochul’s recent Executive Budget release indicated that New York intends to send that document to CMS in March 2022. This means a draft waiver amendment document should be released soon, to allow the state to conduct another public comment process before formally submitting the amendment. That draft will likely reflect much more detail about focuses and priorities for VBP. Stay tuned – we’ll have more to share as the state reveals more about its path forward.
