CMS Releases Guidance on 2018 Measure Changes for Children and Adults

On November 14, Centers for Medicare & Medicaid Services (CMS) released 2018 Updates to the Child and Adult Core Health Care Quality Measurement Sets.

For the 2018 Child Core Set update, the Center for Medicaid & CHIP Services (CMCS) will add three measures: 

  • Screening for Clinical Depression and Follow-Up (CDF) (NQF #3148)
  • Contraceptive Care (NQF #2903) - Most & Moderately Effective Methods 
  • Asthma Medication Ratio (NQF #1800) 

For the 2018 Adult Core Set update, CMCS has decided to add three measures to the Adult Core Set: 

  • Asthma Medication Ratio (NQF #1800) 
  • Concurrent Use of Opioids and Benzodiazepines 
  • Contraceptive Care - Most & Moderately Effective Methods (NQF #2903) 

See the full CMS Informational Bulletin for added and retired core measures with explanations.

Learn how SAE can help with measure reporting for special populations to improve performance outcomes across children and adult services.

SAE Continues to Strengthen Substance Use Disorder Team of Experts, with Emphasis on Opioid Addiction

In response to America's growing opioid crisis, SAE assembled a team of leading professionals with addiction treatment expertise in program development and expansion, maintaining regulatory compliance, maximizing revenue, licensing, achieving fiscal efficiency, and measuring outcomes and quality of care. Members of the team also function as content experts to strengthen grant submissions for providers that seek federal, state, and county funding to treat substance abuse. Below are brief descriptions of our team members' level of expertise. We are assisting community providers and government agencies, so let us know how we might assist you.

Our Team

Team Leader Steven Rabinowitz recently retired after 30 years of service at NY State Office of Alcoholism and Substance Abuse Services (OASAS), where he spent the last 11 years as the Director of Downstate Field Operations, overseeing funding and program services in NYC and Long Island for over 250 substance abuse prevention, treatment, recovery and specialized services provider agencies, and supervised 35 staff associates. Besides his thorough knowledge of fiscal, programmatic and operational issues facing provider agencies, Steve was heavily involved for the last few years with initiatives like managed care, health homes, DSRIP, HCBS, Value-Based Payments, as well as serving as co-leader of a major internal reorganization effort within OASAS.

Bruce G. Trigg, MD, is a public health physician who worked for 23 years with the New Mexico Department of Health, where he was the medical director for the Sexually Transmitted Disease (STD) Program. He led the effort to implement a public health and methadone maintenance program at the Bernalillo County Metropolitan Detention Center in Albuquerque. Dr. Trigg helped to develop and expand the statewide harm reduction program, including a needle and syringe exchange program, buprenorphine treatment, and overdose prevention with provision of naloxone. Since retiring from the Department of Health in 2011, Dr. Trigg has been the medical director for Opioid Treatment Programs in New Mexico. He has worked with the University of New Mexico ECHO (Extension for Community Healthcare Outcomes) Program, a collaborative model of medical education and care management, and was on the faculty for physician buprenorphine waiver trainings.

Frank McCorry, PhD, has worked in the field of substance abuse prevention and treatment for over 35 years. His most recent assignments have focused on clinical policy and practice improvement issues, particularly in the areas of public health, co-occurring mental health and addictive disorders and managed care. He has represented OASAS on a joint initiative with the Office of Mental Health on co-occurring disorders, which is based on the “New York Model”, a conceptual paradigm for the treatment of persons with co-occurring disorders and has served as principal investigator for numerous research projects related to his areas of interest. Dr. McCorry is Chair of the Washington Circle Group, a SAMHSA-sponsored initiative to develop substance abuse performance measures for use in managed care and public sector settings, co-Chair of the National Quality Forum’s Voluntary Census Standards, and an Editorial Board Member of Journal of Substance Abuse Treatment. Dr. McCorry received his doctorate in Counseling and Human Services from St. John’s University.

Brian M. Baldwin, LCSW, has extensive experience in Program Evaluation and Compliance. He has previously worked in the NYS OMH Division of Quality Management and Bureau of Inspection and Certification, and currently heads Baldwin Consultants. During his years at OMH, Mr. Baldwin conducted on site evaluations of most of the inpatient, outpatient and residential mental health programs in the metropolitan area. Baldwin Consultants has provided Comprehensive Program evaluations for inpatient psychiatric hospitals, outpatient mental health and substance abuse programs as well as consultation on medical record documentation and Assessment and Treatment Planning instruments design. Mr. Baldwin also has extensive experience in the substance abuse treatment field as a Program Director with the New York State Drug Abuse Control Commission and as a Consultant developing inpatient and outpatient substance abuse programs, as well as providing Program Evaluation services for Substance Abuse Treatment Programs.

William Panepinto, LMSW, has an over 30-year history of government and consultation experience serving non-profits targeting vulnerable homeless populations and individuals with substance abuse issues. His career has included ten years of treatment experience and 25 years of state government work with OASAS. At OASAS, he brought addiction specialty care to Community Health Centers and NYC Homeless Shelters in the 1980s, and HUD Shelter Plus Care Homeless Permanent Housing grants to NYS communities in the 1990s. Under his leadership as the first Director of Bureau of Housing Services for OASAS from 2007 to 2013, the agency's Housing Portfolio increased from 850 units in NYC and ten other counties, to over 2,200 units in NYC and thirty additional counties. Recently, Bill designed the OASAS New York/New York III Homeless Initiative for Single Adults and for Families, and the OASAS MRT Supportive Housing Initiative.  Since March 2015, he has have worked as the Director of Special Projects, a part-time position for St. Joseph's Addiction Treatment and Recovery Centers. His focus has been on supportive housing, residential redesign, and co-location of primary health care and behavioral health care.

Additionally, the team will be supported by the operational, hands-on experience of Shelley Scheffler and John Sheehan.

Shelley Scheffler, PhD, LCSW-R, is an early adopter of the theory and practice of integrated care and has dedicated her career to promoting it in different healthcare and treatment settings. As Vice President of Practice Innovations at Services for the UnderServed, she was instrumental in transitioning the organization to an integrated care model with new initiatives such as the Trauma Informed Care Project, including a Zero Suicide effort, and participation in the SAMHSA learning collaborative to integrate primary care into substance use treatment. Prior to this, Dr. Scheffler was the Senior Integrated Care Specialist at the Center for Excellence in Integrated Care (CEIC), a project was funded by the New York State Health Foundation to promote co-occurring capability in substance use and mental health treatment services throughout New York State. Dr. Scheffler has also provided technical assistance to FQHC's, providing organizational training and detailed outcome analysis. In her career, she has had administrative experience leading case management and substance use services at a large hospital center. She has developed workshops on trauma, substance use, homelessness as well as other social issue topics. Dr. Scheffler has taught at the NYU Silver School of Social Work, the Simmons School of Social Work and the Fordham University CASAC Program.

John Sheehan, LMSW, has focused his 35+ year career serving the substance use and homeless populations including adolescents. Starting his career as an outreach worker, Mr. Sheehan held the position of Vice President at Phoenix House and has held leadership roles at Project Samaritan, Outreach Project, and Bowery Residents Committee, where he served as Deputy Executive Director overseeing Programs for the Homeless Mentally Ill and Chemically Dependent. In addition to his consultant work with SAE & Associates, John has worked with All Souls Church and the 5th Avenue Presbyterian Church to develop social services programs for the homeless. Mr. Sheehan has been honored for his dedication by Phoenix House Foundation and does extensive volunteer work for the MS Society. He is a graduate of Adelphi University with both a Bachelors Degree and Masters Degree in Social Work. He has a Certificate in Non-profit Management from NYU Robert Wagner School. He also has completed trainings recently in Mindfulness and PTSD.

Grant Seeking: Finding a Fit

Grants are opportunities to expand program offerings as well as specialize and build expertise.

A grant award is a recognition of the applicant's commitment to serve. However, a grant submission is an initial commitment of vision and resources for the applicant. Each submission narrative is a strategic planning roadmap of need, capacity, strengths, community recognition and support, and a promise of performance. The submission must make sense in its flow of content and build a narrative that speaks to the applicant's current understanding, expertise, mission, services and compelling ability to actualize new care and services.

How does one go about finding the 'right' grant to apply for?

How does a grant submission start?

Government grants can be found on grants.gov, which lists the steps below for grant seekers.

  1. Learn: Go to the Grants Learning Center for an overview of grants.
  2. Check: Make sure you are eligible before applying.
  3. Search: Find federal grants that align with your work.
  4. Register: Sign up with grants.gov to apply using Workspace.
  5. Apply: Complete and submit your application using Workspace.
  6. Track: Enter your Grants.gov tracking number(s) for submission status. 

While the above steps are very succinct and simple, experienced grant seekers know there is a process for each step, and knowing which grant you will be the most competitive applicant for is an essential first step. Below is the list of anticipated areas of focus for the grant season beginning fall 2017.

Comprehensive Community Mental Health Services for Children with Serious Emotional Disturbances (SED)

  • Fiscal Year 2018: It is estimated 41 awards will be made.

Protection and Advocacy for Individuals with Mental Illness 

  • Fiscal Year 2018: It is estimated 57 awards will be made.

Projects for Assistance in Transition from Homelessness (PATH) 

  • Fiscal Year 2018: It is estimated 56 awards will be made.

Substance Abuse and Mental Health Services Projects of Regional and National Significance

  • Fiscal Year 2018: It is estimated 815 awards will be made.

Drug-Free Communities Support Program Grants

  • Fiscal Year 2018: No Current Data Available

PPHF Cooperative Agreements for Prescription Drug Monitoring Program Electronic Health Record (EHR) Integration and Interoperability Expansion

  • Fiscal Year 2018: Multi-year funding for a total of two 12 month incremental periods within a two-year/24-month project period.

Opioid STR

  • Fiscal Year 2018: It is estimated 55 awards will be made.

CARA Act - Comprehensive Addiction and Recovery Act of 2016

  • Anticipated Total Available Funding:$2,750,000. 
  • Estimated Award Amount: Up to $50,000.

Block Grants for Community Mental Health Services

  • Fiscal Year 2018: It is estimated 59 awards will be made.

Mental Health Disaster Assistance and Emergency Mental Health

  • Fiscal Year 2018: No Current Data Available.

Assisted Outpatient Treatment

  • Fiscal Year 2018: It is estimated 16 awards will be made.

Although the grant season has started with the first SAMHSA funding opportunity announcement (FOA), it's not too late for organizational planning level work to identify which grants fit you best.  Start building a framework that details how your organization is a competitive applicant by identifying the following elements:

  • outstanding performance data,
  • populations of need and interest,
  • innovative treatment designs addressing barriers to care, and
  • unique community positioning. 

Strategically target grant releases that demonstrate a fit with these elements. Finding your fit is an essential first step toward a compelling and competitive grant submission.

NYS DOH Updates on PPS Progress and Provider Contract Guidelines for IPAs

NYS DOH Announces Provider Contract Guidelines for Article 44 MCOs, IPAs and ACOs

New York State Department of Health (DOH) released Provider Contract Guidelines for Article 44 MCOs, IPAs, and ACOs with the intent of establishing standards for contract submission and review, clarifying required contract provisions, and effectuating the provisions of Article 44 of the Public Health Law and 10 NYCRR Part 98.

"These Guidelines are applicable only to contracts that allow for the arrangement, or provision of Health Care Services and Technical and Administrative Services incidental thereto. The Guidelines incorporate all provider reimbursement arrangements, including value based and traditional arrangements. Reference to the New York State Value Based Payment Roadmap (Roadmap) applies to Medicaid lines of business only. However, MCOs with commercial lines of business may use, in its own discretion, concepts from the Roadmap. Care management administrative service agreements and Health Home agreements do not come under the scope of these Guidelines."

NYS DOH Releases PPS Progress through DY3, Q1

NYS DOH's recent reporting of the Performing Provider Systems (PPS) Progress indicates a substantial increased amount of funds flowed to network partners. As of June 2017, PPS have distributed 85% of all dollars earned ($878 million) to various categories of downstream partners. 

"During the DSRIP Mid-Point assessment (MPA) process in February 2017, the DSRIP Project Approval and Oversight Panel (PAOP) encouraged PPS to increase their distribution of funds to network partners. As a result, PPS funds distributed to network partners increased by 112% or double the amount of cumulative distributions prior to the DSRIP mid-point."

To be a recognized and valued network partner, building your value proposition is critical. It must address key strengths, opportunities, outcomes, risks and responsibilities. It must be versatile as well as specific in citing relevant impact on cost of care and alignment with population risk variables. 

HHS Issues Guidance for Clarity on HIPAA as It Relates to Opioid Overdose

In response to the declaration of a nationwide public health emergency regarding the opioid crisis, the U.S. Department of Health & Human Services (HHS) Office for Civil Rights released new guidance for healthcare providers. The guidance addresses how and when healthcare providers can share patient health information with her/his family, friends, and legal personal representatives when that patient may be in crisis and incapacitated, such as during an opioid overdose, without violating HIPAA privacy regulations.

"Sharing health information with family and close friends who are involved in care of the patient if the provider determines that doing so is in the best interests of an incapacitated or unconscious patient and the information shared is directly related to the family or friend's involvement in the patient's health care or payment of care. For example, a provider may use professional judgment to talk to the parents of someone incapacitated by an opioid overdose about the overdose and related medical information, but generally could not share medical information unrelated to the overdose without permission."

View the full HHS HIPAA guidance

For information on Executive Coaching on addiction treatment models of care, click here. To connect with our experts in addiction treatment, call (212) 684-4480 or email info@saeassociates.com.

CCO/HH Applications to Serve Individuals with Intellectual and/or Developmental Disabilities Due November 30 

This month, Kerry Delaney, Acting Commissioner of the Office for People With Developmental Disabilities (OPWDD), announced the final Care Coordination Organization / Health Home Application to Serve Individuals with Intellectual and/or Developmental Disabilities. Click here to view the full announcement.

Applications are due November 30, 2017, and application documents can be found on the Department of Health (DOH) website.

If you are interested in this opportunity and would like to explore how we can help you in this arena, call (212) 684-4480 to connect with one of our lead experts in developmental disabilities, Allen Schwartz. 

More on Allen Schwartz:

Allen A. Schwartz, PhD, is a licensed psychologist who started his career implementing the Willowbrook Consent Decree in New York City as part of the newly formed Office for People with Developmental Disabilities (then OMRDD). He spent 33 years in state government as a leading "change champion" for OPWDD, designing innovative services and supports. OPWDD is now a $10 billion human services agency in New York serving 130,000 people with I/DD and their families in partnership with over 450 not-for profit providers. He was responsible for leading OPWDD's transition to person-centered planning and individualized services, and designed and implemented consumer-directed services within OPWDD's HCBS waiver. He worked for three years at the Westchester Institute for Human Development (a University Center for Excellence in I/DD) on a five-year self-determination project with a consortium of five participating states. He helped formulate policy and curricula content for this National Training Initiative, and developed tools, research materials, and policy papers to assist states and organizations in scaling up their promotion of self-advocacy, self-direction, and health literacy.

New York State Departments Host Webinar Addressing Children's Medicaid Transformation

Early this month, the New York State Departments (Department of Health, Office of Mental Health, Office of Alcoholism & Substance Abuse Services, Office of Children and Family Services, and Office for People with Developmental Disabilities) hosted their monthly Children's Medicaid Transformation webinar. Slides from that webinar are posted on the Department of Health website.

Contents of the webinar included the following:

  • 1915c Provider Readiness Transition to Health Home Care Management
  • Provider Designation
  • HCBS and SPA Billing and Rates
  • Upcoming Trainings
  • Questions and Answers

Learn About SAE's Services for Children HCBS and Managed Care Service Transition

Executive Coaching Available in the Field of Addiction Treatment

With changing requirements and opportunities in the service field, a guided approach for development can be helpful. Linking to a coach who understands the service history and also the current demands in service delivery and service outcomes can yield lasting results. Expert coaching is supportive, informative, and personalized.

Expert coaching can help with:

  • identifying opportunities for business growth;
  • developing action plans for challenges;
  • staying updated on moving policies, plans, and requirements; and
  • systematizing operational goals to match service opportunities.

SAE's Executive Coaching services are now available in the following areas: addiction treatment, evaluation, population health, mental health Parity.

Our coaching services include:

  • a termed timeline to engage in scheduled coaching sessions for members of your team;
  • think tank sessions that are focused and informed;
  • services tailored and specialized to the demands, interests, and concerns of your service agency's needs; and
  • developed team action steps to track potential for change and define business goals.

Bruce G. Trigg, MD, one of our addiction treatment experts, is a public health physician who worked for 23 years with the New Mexico Department of Health as the medical director for the Sexually Transmitted Disease (STD) Program. He led the effort to implement a public health and methadone maintenance program at the Bernalillo County Metropolitan Detention Center in Albuquerque. Dr. Trigg helped to develop and expand the statewide harm reduction program, including a needle and syringe exchange program, buprenorphine treatment, and overdose prevention with provision of naloxone. Since retiring from the Department of Health in 2011, Dr. Trigg has been the medical director for Opioid Treatment Programs in New Mexico. He has worked with the University of New Mexico ECHO (Extension for Community Healthcare Outcomes) Program, a collaborative model of medical education and care management, and was on the faculty for physician buprenorphine waiver trainings.

For more information on how to benefit from SAE's Executive Coaching services, 

call (212) 684-4480 or email info@saeassociates.com.

HANYS Hosts SAE's Presentation on Managing Utilization Review in Light of Parity

Early this month, SAE headed to Tarrytown, New York to present at the Behavioral Health and Primary Care Strategies, Weapons, and Tactics (SWAT) conference, hosted by Healthcare Association of New York State (HANYS). This year's SWAT program, Strategies for Success, was designed to provide guidance on the competencies and skills needed to tackle redesigning the primary care system, understand the risks and rewards of value-based payment, integrate services, and address payer denials.

The Mental Health Parity and Addiction Equity Act (MHPAEA) and its regulations were passed and implemented to end discriminatory health insurance practices against those with mental health and/or substance use disorder issues. Unfortunately, obstacles to treatment continue to persist within the health insurance industry. During SAE's presentation at the HANYS conference, the Parity Compliance team focused on helping attendees:

  • understand the basic medical necessity elements for the level of care being requested to make sure the patient meets those requirements;
  • know what to look for in a denial letter and determine if the criteria applied are appropriate;
  • know the essential ingredients for a properly constructed appeal;
  • understand what date must be maintained in order to monitor and manage denials and appeals; and
  • learn how to organize and analyze the data on a payer-specific basis to target improvement opportunities that yield more revenue or lower internal administrative costs.

A Compliance Alert from the NYS Office of the Medicaid Inspector General

For providers under the New York Medicaid program, they must consider their compliance program's risk assessment activity and how the many various service reimbursement models may impact required risk assessment factors, clinical and administrative processes, and clinical and billing outcomes.  

The following are all identified factors to monitor and ensure compliance to requirements under 18 NYCRR § 521.3: 

  1. billings; 
  2. payments; 
  3. medical necessity and quality of care; 
  4. governance; 
  5. mandatory reporting; 
  6. credentialing; and 
  7. other risk areas that are or should with due diligence be identified by the provider. 

Read about NYS OMIG's participation in the National Healthcare Fraud Takedown

Call (212) 684-4480 or email info@saeassociates.com to learn about how SAE can help with OMIG audits.

HCBS Guidance for NYS Children's Medicaid System Transformation

Recently, the NYS Department of Health (DOH), Office of Alcoholism & Substance Abuse Services (OASAS), Office of Children & Family Services (OCFS), Office of Mental Health (OMH), and Office for People With Developmental Disabilities (OPWDD) have been releasing materials to address the Medicaid Children's System Transformation. It is essential for providers to stay abreast of the key elements of the children's transformation. SAE's HCBS Consulting Team can help your provider agency launch your HCBS program. Our approach involves identifying the financial and clinical implications of New York's transition to HCBS for your agency, exposing potential red flags, ensuring that your current strengths are maintained throughout the transition, etc.

View our HCBS Consulting Services Overview to learn about how we can assist you in this arena. SAE aims to ensure that providers successfully launch and sustain their HCBS initiatives.

Managed Care Contract Analysis for Value-Based Payment

Managed care contracting is a priority in value-based payment (VBP) agreements. 

Before attempting a VBP agreement with a managed care organization or setting up a VBP linkage relationship, you should have a comprehensive understanding of negotiated rates and payer mix.

  • Understand the risk management issues that impact outcomes and are related to your client population.
  • Define and develop a strategic book of services/products that optimizes the expected outcomes for reimbursements.
  • Analyze claim history with current services to contain revenue cycle impact of new services and new contracts.
  • Identify risks for denials and provide management infrastructure to contain and maximize service growth and relationships.
  • Analyze current contracts well before they expire because a managed care negotiation is not a quick process and will, more than likely, require multiple conversations.
  • Be prepared that new services or products may impact current contracts that may be terming.

Our managed care consulting team has years of experience in managed care contract analysis for both adult and children services.

Individual contracts can be reviewed and recommendations will be offered regarding rates, next steps in provider negotiations and alignment with VBP. All teams and projects are tailored to your specific service targets and products.

SAE is pleased to announce a lead expert in managed care contract analysis:

JOSEPH MARAFITO, MS

CONSULTANT ADOLESCENT, DISABILITY AND SUBSTANCE ABUSE

Over 20 years of progressive supervisory, program development and administrative experience in both the public and private sectors. Expertise in program evaluation, public policy, fiscal management, revenue enhancement, program development, regulatory issues, residential and community outpatient services. Worked with executive and legislative branches of government through policy committees and workgroups advising branch administrators on system development and policy related matters. Accomplished significant population reduction over a two year period at the beginning of the deinstitutionalization movement in CT, developed agency in CT that provided community based services and eventually lead to the first supported living program in CT, co-wrote and negotiated substance abuse grants and transitioned adult residential program to adolescent residential and out-patient services.

To connect with our team, call (212) 684-4480 or email info@saeassociates.com.

National Guidance from CMS and SAMHSA with Parity Defined for Consumers

The Centers for Medicare & Medicaid Services (CMS) Office of Minority Health and the Substance Abuse & Mental Health Services Administration (SAMHSA) recently released a guidance on how to communicate about social and behavioral health services to consumers. The Roadmap provides clear steps for treatment and recovery with checklists and sample forms to gather information, as well as information on Mental Health and Substance Addiction Parity requirements. Also included in this document is a glossary of terms to explain technical Parity language that may be cumbersome to understand.

Click here to download the Roadmap: https://www.cms.gov/About-CMS/Agency-Information/OMH/Downloads/Coverage-to-Care-Behavioral-Roadmap.pdf

Upcoming Webinar on NYS Children's Medicaid System Transformation

NYS Department of Health (DOH), Office of Alcoholism & Substance Abuse Services (OASAS), Office of Children & Family Services (OCFS), Office of Mental Health (OMH), and Office for People With Developmental Disabilities (OPWDD) will be hosting a joint webinar presentation on Monday, September 18 from 1:00PM to 2:30PM. The webinar will focus on the Medicaid Children's System Transformation. They will provide a refresher course on the key elements of the children's transformation, including timeframes, expansion of services, transition to Medicaid Managed Care, and important readiness activities that providers should be engaged in now. They encourage Health Home leadership, care management agencies, current 1915(c) Waiver providers, applicants for expanded services, and all interested stakeholders to attend.

Click here to register for the Children's Medicaid System Transformation Overview/Refresher.

You can also view our HCBS Consulting Services Overview to learn about how we may be able to assist you in this arena.

The Importance of an IPA

Independent Practice Associations (IPA) are organized associations or collaboratives designed to negotiate service reimbursements for specific services with insurance companies on behalf of the contracted providers compensated with a negotiated capitation or modified fee-for-service model. The benefits of an IPA reduce risk to any one participating provider and allow shared costs across all providers. 

With a well-developed service strategy comes greater bargaining power. Whether the IPA encompasses all specialties within a geographic area or represent a single specialty with broad capacity, the services are defined and recognized as value added beyond the expected norm. The “value added” service of the IPA is shared, communicated and tracked with a thoughtful metrics definition that forecasts risks as well as generates performance reports and points to quality improvement reviews. A shared administrative business function should capture, collect and communicate to ease the delivery of care as well as track and ensure referral and landing of services.

Executive Coaching from SAE Now Available!

With changing requirements and opportunities in the service field, a guided approach for development can be helpful. Linking to a coach who understands the service history and also the current demands in service delivery and service outcomes can yield lasting results. Expert coaching is supportive, informative, and personalized.

Expert coaching can help with:

  • identifying opportunities for business growth;
  • developing action plans for challenges;
  • staying updated on moving policies, plans, and requirements; and
  • systematizing operational goals to match service opportunities.

SAE's Executive Coaching services are now available.

Our coaching services include:

  • a termed timeline to engage in scheduled coaching sessions for members of your team;
  • think tank sessions that are focused and informed;
  • services tailored and specialized to the demands, interests, and concerns of your service agency's needs; and
  • developed team action steps to track potential for change and define business goals.

Steven Rabinowitz is a member of our Executive Coaching team. Rabinowitz recently retired after 30 years of service at the NY State Office of Alcoholism and Substance Abuse Services (OASAS), where he spent the last 11 years as the Director of Downstate Field Operations, overseeing funding and program services in NYC and Long Island for over 250 substance abuse prevention, treatment, recovery, and specialized services provider agencies. Besides his thorough knowledge of fiscal, programmatic, and operational issues facing provider agencies, Steve was heavily involved for the last few years with initiatives like managed care, health homes, DSRIP, HCBS, and Value-Based Payments, as well as serving as co-leader of a major internal reorganization effort within OASAS.

For more information on how to benefit from SAE's Executive Coaching services, you can email info@saeassociates.com or call (212) 684-4480.

CMS to Cancel Mandatory Cardiac, Expanded Joint Replacement Bundles

Earlier this month, the Centers for Medicare and Medicaid (CMS) proposed a rule to the Office of Management and Budget that would stop programs scheduled to launch January 2018. Both cardiac and joint replacement programs were proposed just over a year ago, with an original launch date of July 2017 and were previously delayed. CMS may issue a new rule to continue the Bundled Payments for Care Improvement (BPCI) initiative, a voluntary program that had been scheduled to end in 2018. The new version of BPCI may allow qualification as an Advanced Alternative Payment Model (APM) under the Medicare Access and CHIP Reauthorization Act (MACRA).

Value-Based Bundle Payment Models must be tied to health analytics that use risk stratification and population health metrics. Feel free to email info@saeassociates.com for more information. 

Mental Health Parity under the ACA and Cures Act

The 21st Century Cures Act, signed by President Obama on December 13, 2016, requires the Department of Labor, the Treasury, and Health and Human Services to solicit public responses and feedback on how to improve disclosures of health plan benefits in compliance with the Mental Health Parity & Addiction Equity Act of 2008 (MHPAEA).

In Section 13007 of the Cures Act, coverage for eating disorder benefits must be consistent with the requirements of MHPAEA.

The Departments' recent FAQ, released in June, defines eating disorder as a mental health condition and is requesting public comment on how MHPAEA apply to the treatment of Eating Disorders.

SAE understands the administrative and clinical complexity of eating disorder treatment. Professional services, such as nutrition services, need to be part of an outpatient team approach. However, essential components for eating disorder treatment or the continuum of treatment care have not always been approved for eating disorder patients. Additionally, "medical necessity" determinations should not be ascertained by weight only; indeed, clinical criteria for varying levels of care determinations need to be inclusive of psychiatric functional assessment. Otherwise, there are inherent concerns of non-quantitative treatment limitations (NQTLs). 

SAE will be submitting a public comment for the Departments. 

All comments to the Departments about eating disorders are due September 13, 2017 to:

e-ohpsca-mhpaea-eating-disorders@dol.gov.

NYS Develops Draft Transition Plan for the Children's Medicaid System Transformation

New York State has developed a DRAFT Transition Plan for the Children's Medicaid System Transformation. The draft Transition plan (subject to approval by Centers for Medicare & Medicaid Services) is being shared with interested stakeholders for review and comment.

Comments are due August 31, 2017 by email to BH.Transition@health.ny.gov, with the subject line: "Draft Children's Transition Plan Comments". In your comments, indicate the section and page number to which your comment refers to.

The State will also hold a statewide webinar on August 24, 2017 at 3PM to review the Draft Transition Plan in detail to assist stakeholders. You can register for the webinar here: 

https://attendee.gotowebinar.com/register/2231325092871212547.