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New York Partnership Plan - Amendment to serve Incarcerated Individuals

DateResponseResponse
Nov 20th 2016 2:23 pm Response: #226953 Re: 225837
The goals of the Delivery System Reform Incentive Payment (DSRIP) program include reducing avoidable hospitalizations and health care costs, as well as improving health outcomes. The Innovation Fund is an important tool for identifying gaps in communication and coordination between the diverse community stakeholders that singly and together represent social determinants to health promotion and disease prevention.
For over 25 years, St. Ann's Corner of Harm Reduction (SACHR) has worked extensively at the community and individual level cultivating trust within the community through science-based health promotion education and resources. One lesson we take away from this 26+ year history is SACHR has been strongest in its impact when it has worked within networks--with vulnerable participants as with community providers. The Innovation Fund will be an equal vehicle for learning and experimenting with different approaches as it will be for implementation and evaluation.
SACHR strongly encourages the CMS' support and ample funding for a strong Innovation Fund.
Nov 20th 2016 2:49 pm Response: #226957 Center for Independence of the Disabled, New York (CIDNY) is a non-profit organization founded in 1978. CIDNY’s goal is to ensure full integration, independence and equal opportunity for all people with disabilities by removing barriers to full participation in the community. CIDNY helps consumers understand, enroll in and use private and public health programs, including Medicaid. CIDNY advocates for policies that remove barriers to health coverage that support their integration and success living in the community. People with disabilities are disproportionately incarcerated in New York State. People with disabilities are also disproportionately using public coverage including Medicaid for the health care. For these reasons CIDNY supports New York’s request for a federal waiver to Medicaid rules barring the use of Medicaid for incarcerated individuals. Using Medicaid to pay for certain services that would help individuals transition from incarceration back to the community would insure that incarcerated individuals with disabilities would be connected to treatment, medication support and intensive care coordination prior to release, instituting a continuum of care and thereby improving their health. Disruptions in medical care upon reentry lead to poor and costly health outcomes use and re-incarceration, including a 12-fold rise in the risk of death in the first two weeks post-release. Providing the needed array of transitional services would significantly increase the chances of a successful reentry into the community. CIDNY urges approval of this Plan Amendment so that incarcerated people with disabilities can get the health services they need to maintain their health and independence. For further information, please contact Heidi Siegfried, CIDNY’s Health Policy Director, at 646-442-4147 or hsiegfried@cidny.org
Nov 20th 2016 2:57 pm Response: #226961 Thank you for your consideration. Please feel free to reach out with questions at leo_eisenstein@hms.harvard.edu
Nov 20th 2016 3:09 pm Response: #226965 Center for Independence of the Disabled, New York (CIDNY) is a non-profit organization founded in 1978. CIDNY’s goal is to ensure full integration, independence and equal opportunity for all people with disabilities by removing barriers to full participation in the community. CIDNY helps consumers understand, enroll in and use private and public health programs, including Medicaid, and benefits, services, housing, education and training, and supports that we characterize as social determinants of health.

This comment is in reference to Response #225837 and supports the Communities Together for Health Equity (CTHE), a coalition of community-based organizations (CBOs), in seeking an amendment to implement the DSRIP Innovation Fund. The Innovation Fund provides the financial means for local community groups to bring their best practices and deep experience to help meet the overall DSRIP goals.

The Innovation Fund sets aside 5% of annual funding for CBOs to join with their local PPSs to implement community projects that have enormous potential to improve the well-being and reduce hospital use. At this time, the state proscribed DSRIP projects allow little practical potential for community groups to participate; nor did the “top down” planning of DSRIP allow local communities to bring forward their best ideas and practices.

There are many examples of evidence-based strategies and projects that communities could implement with the Innovation Fund support. These included helping people with disabilities access and maintain the benefits, services, housing, education and training, and other supports they need to stay healthy and live successfully in the community

Specifically, the DSRIP Innovation Fund calls for 5% percent of PPS allocations through years 3 to 5 to be set aside. PPSs and community partners would work together to review local needs and conditions and select projects to receive Innovation Fund grants. The Innovation Fund will follow some of the guidelines set out by the state (in its RFP for a CBO Strategic Planning Consortium): reserved for community groups that do not provide clinical services or have clinical licenses.

This fund represents a crucial step towards connecting the services patients receive in the hospitals with the support they need outside, starts to address the many social determinants of health that everyone has agreed DSRIP must confront.
Nov 20th 2016 3:37 pm Response: #226969 November 20, 2016 Mr. Eliot Fishman, Director Center for Medicaid and CHIP Services (CMCS) Centers for Medicare & Medicaid Services 7500 Security Blvd, Mail Stop S2-01-16 Baltimore, Maryland 21244-1850 Re: Proposed 1115 Medicaid waiver authorizing Federal Medicaid matching funds for certain transitional services provided in a 30-day period immediately prior to release to incarcerated individuals with serious behavioral and physical health conditions Dear Mr. Fishman: Second Chance Reentry, Inc., strongly supports the NYS Department of Health’s proposal to seek an 1115 waiver from the federal Centers for Medicare & Medicaid Services (CMS) authorizing federal Medicaid matching funds for certain transitional services provided in a 30-day period immediately prior to release to incarcerated individuals with serious behavioral and physical health conditions in New York, who are eligible for Health Homes under the Affordable Care Act § 2703. The vital importance of this proposal is not simply an increase in Federal tax dollars to support the health care of soon to be released inmates, but it is the impetus required to ensure a successful transition process for incarcerated individuals with chronic physical and mental health conditions, so they are informed about the correct way to utilize Medicaid services. As a formerly incarcerated individual living with a chronic illness, I chose to hide my illness while incarcerated to avoid the subpar medical treatment provided in a correctional setting. All too often, inmates that are denied adequate care in prison tend to ignore their health conditions, to avoid the indignation of having to beg for health care or worse, being stigmatized by correctional staff and inmates. Thus, the delay in medical treatment only exacerbates the condition, and requiring more expensive treatment upon release. Therefore, the NYS Department of Health’s proposal to seek an 1115 waiver from the federal Centers for Medicare & Medicaid Services (CMS) authorizing federal Medicaid matching funds for certain transitional services is a cost cutting measure if nothing else, and should be supported. Thank you for the opportunity to comment. Sincerely, Sandy Guillaume Sandy Guillaume, MPA Executive Director, Second Chance Reentry, Inc Board of Directors: Patricia Dellatto, Chairperson; Tina Wolf, Vice-Chairperson; Pam Neely, Director; Barbara Allan, Director Serena Ligouri, Director; Barbara Sisti, Director
Nov 20th 2016 4:30 pm Response: #226973 The New York Immigration Coalition writes in reference Response #225837 to support the DSRIP Community Innovation Fund The Innovation Fund provides the financial means for local community groups to bring their best practices and deep experience to help meet the overall DSRIP goals.

The Innovation Fund sets aside 5% of annual funding for CBOs to join with their local PPSs to implement community projects that have enormous potential to improve the well-being and reduce hospital use. At this time, the state proscribed DSRIP projects allow little practical potential for community groups to participate; nor did the “top down” planning of DSRIP allow local communities to bring forward their best ideas and practices.

There are many examples of evidence-based strategies and projects that communities could implement with the Innovation Fund support. Some examples: extra food provided to reduce end-of-month diabetes-related emergencies when food stamps run out, peer educator-delivered chronic disease self-care education, tailored local mentoring to reduce clinical utilization by youth with behavioral challenges, doulas to provide maternal mental health services. These are just a few of the many possibilities.

If we truly hope to achieve DSRIP’s goals, let us do so by allowing these and other much needed, evidence-based, community programs to be DSRIP-funded.

Specifically, the DSRIP Innovation Fund calls for 5% percent of PPS allocations through years 3 to 5 to be set aside. PPSs and community partners would work together to review local needs and conditions and select projects to receive Innovation Fund grants. The Innovation Fund will follow some of the guidelines set out by the state (in its RFP for a CBO Strategic Planning Consortium): reserved for community groups with annual budgets of $5 million or less and groups that do not provide clinical services or have clinical licenses. However, it should include CBOs that are Health Home members, that bill Medicaid for other than clinical/licensed services.

This fund represents a crucial step towards connecting the services patients receive in the hospitals with the support they need outside, starts to address the many social determinants of health that everyone has agreed DSRIP must confront.
Nov 20th 2016 5:27 pm Response: #226981 Please see the attached comments from Herminia Palacio, MD, MPH, New York City Deputy Mayor for Health and Human Services.
Nov 20th 2016 7:48 pm Response: #226989 The Legal Aid Society submits the attached comments in support of New York State's waiver proposal authorizing federal Medicaid matching funds for transitional services for incarcerated persons immediately prior to release.
Nov 20th 2016 8:39 pm Response: #226993 November 20, 2016
Harm Reduction Coalition, a New York-based national organization working to address the health consequences of substance use, is in full support of the New York Partnership Plan - Amendment to Serve Incarcerated Individuals. Many individuals leaving state and county correctional facilities have significant behavioral health needs. A smooth transition to mental health and substance use disorder treatment can dramatically ease the return of citizens to the community. Opioid overdose deaths among this population are a major concern. People leaving the criminal justice system are at a far greater risk of opioid overdose mortality, with studies document overdose fatality rates 5- to 100-fold greater than the general population. Several health interventions covered by Medicaid have been shown to reduce opioid overdose deaths. The provision of naloxone, the medication which prevents an evolving overdose from becoming fatal, is currently being provided to many inmates in New York State as they are released. This program needs to be supported in a sustainable manner. Not only does it have the potential to prevent deaths among people newly released from incarceration, it also enables them to return to communities with a life-saving tool. Medication-assisted treatment with methadone or buprenorphine has also been shown to reduce the risk of overdose deaths by as much as 80%. These services are rarely provided through the course of incarceration in this country despite evidence of success. However, initiation of these services prior to release has been shown to be both feasible and efficacious in transitioning to the services in the community. Harm Reduction Coalition supports the full Plan Amendment and particularly coverage for provision of naloxone upon release and access to buprenorphine and methadone maintenance prior to release.
Sharon Stancliff, MD, FASAM
Medical Director Harm Reduction Coalition
New York, NY
www.harmreduction.org
Nov 20th 2016 9:53 pm Response: #227001 Dear Mr. Fishman,

I am writing in support of the NY Department of Health's 1115 waiver proposal from the Federal CMS which authorizes federal Medicaid matching funds for certain transitional services provided in a 30-day period immediately prior to release for incarcerated individuals with serious behavioral and physical health conditions. I have worked in New York as a nurse for over 30 years in both the hospital and outpatient settings beginning my career caring for folks dying from HIV/AIDS. I have been a witness to the devastation of physical and behavioral health conditions along with the numerous obstacles associated with living with chronic conditions from access to care to financial support for essential medications - add to this the exponential difficulties faced by those individuals who are about to be released from incarceration. Transitional care is finally being recognize as a key crtitical component of improved outcomes and reduced hospitalizations. By passing this proposal in support of applying transitional care for incarcerated individuals 30- days prior to release from the correctional facility we can begin to recognize that ALL individuals are entitled to a healthier life. This first step should also be the beginning of a much larger, more comprehensive discussion about equitable healthcare for all.

Sincerely,

Barbara George, EdD, MSN, AGNP-C
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