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HCA, Partners Assert 1115 Waiver Recommendations 

Today, HCA and six other prominent health care associations wrote to the state’s Deputy Secretary for Health and Human Services Paul Francis with core recommendations and key amendments that the state should consider in its multi-billion-dollar 1115 Medicaid waiver renewal process. (See the letter here.)

Section 1115 of the Social Security Act gives the U.S. Secretary of Health and Human Services the authority to approve state-level experiments, pilots, or demonstration projects in Medicaid and the Children’s Health Insurance Program (CHIP) programs.

New York has used this section of law as the basis for its Medicaid Redesign Team (MRT) initiatives that have fundamentally reshaped the health care system in New York State. The waiver renewal is the state’s opportunity to sustain these initiatives and, possibly, introduce major new ones.

HCA has repeatedly stressed the missed funding opportunities and imbalances that have emanated from the current 1115 waiver construct. Such imbalances, we note, are among many factors that have aggravated a well-documented workforce shortage for community care throughout New York State.

Home care, hospice and other community care providers are also “constantly framed under the [existing] waiver as ‘downstreams’ of other, ostensibly controlling entities, rather than as the primary, preventive and priority-first layers of the system,” whether financially, in the fund flows, or administratively in terms of which sectors are empowered to drive decision-making. Our letter calls for “this execution and practice to be righted.”

A longtime funding void has also prohibited community providers from investing in health information technology connectivity that is critical to meeting the imperative presented to home care, hospice and other providers as part of the very fabric of the 1115 waiver itself, including such initiatives as the Delivery System Reform Incentive Payment (DSRIP) program and value-based payments.

As currently structured, we note, these programs have created incentives — both funding and authority-related — which result in existing community resources getting overlooked. This “duplication, overlap, conflict/confusion and scofflaw risk” needs to be addressed in the form of waiver amendments that create a more bilateral structure, we write.

Our multi-association letter includes a range of other recommendations related to data access for home and community care providers, collaborative model opportunities, innovative payment arrangements and Medicare Maximization.

Please read the full letter for details and HCA will keep you apprised of ongoing discussions about this major policy development commanding attention, including next-step discussions with the Executive and other stakeholders.