There has been a lot of excitement generated as a result of recent open comment periods regarding the 1115 waiver proposal! The comment period indicates the beginning of a negotiation process between NYS Department of Health and the Centers for Medicare and Medicaid Services (CMS), and as such CCN’s partners have understandably begun to have questions about the waiver proposal. As always, CCN is eager to serve as a resource to answer these questions, advocate for its Open Network partners and the region served, and share information as it becomes available.
At the bottom of this page you will find a few helpful links such as the NYS 1115 Waiver Proposal, May public comment sessions, and CCN’s public comments which were submitted to NYS.
“Will Cortland County organizations be able to be a CCN Open Network partner if the proposed geographic region in the 1115 Waiver does not include Cortland County?”
The answer is yes! Regardless of the final parameters of the 1115 waiver, CCN Open Network partners will continue to be able to participate in Open Network programs and services. In the comment paper submitted by CCN on behalf of partners, CCN advocated for flexibility in the geographic regions. Additionally, CCN included six letters of support in its 1115 waiver comments from partner organizations serving Cortland County advocating for Cortland to be included in the Southern Tier region.
“The NYS DOH 1115 waiver makes reference that the State will procure a statewide IT social needs referral and data platform for SDHNs, HEROs, and VBP arrangements to connect the social needs of Medicaid members. Should our organization consider adopting a closed loop referral system? If so, what should we do now? Is CCN going to adopt a closed loop referral system?”
These are great questions. Our short answer is “let time be your friend”. If you haven’t implemented a closed loop referral system, you may want to defer making a decision until the waiver is released since, at this time, we do not know what the State’s final recommendation will be. Ultimately, each organization needs to assess their need for a close loop referral system, urgency to implement, and the options available to address those needs.
During the open comment period, the State received testimony from proponents of singular statewide systems as well as testimony on the importance of the State investing in an integrated approach.
CCN does not believe a statewide IT approach for social interventions is essential to the success of achieving the goals of the waiver. CCN’s recommendation to the state was to deploy IT investments that are informed by the organic workflow of social services delivery. CCN urged DOH to strongly consider leveraging existing infrastructure to avoid further burdening the providers of health and wellness and to support local or regional integration of community and clinical services by focusing on collaboration.
Questions on IT platforms?
The CCN IT Department is available to help navigate decisions. The team stands ready to support our partners now and in the future as the 1115 waiver is unveiled. Additionally, we are also available to provide information and advisement on how the CCN care management and data solutions may support partner organizations in serving their clients and the community.
Questions on the CCN and CCN partners’ position on the 1115 Waiver?
Please join us Friday June 10th for our quarterly Collaborative Connections event (formally our Quarterly Stakeholders meeting) to learn more about the 1115 waiver. You will also learn how a partner organization has integrated health equity, social determinants of health, harm reduction, and technology in the delivery of care; and how they have used “lived experience” to inform their care delivery model. This event is exclusive to Open Network partners.
Additional Resources:
1115 Medicaid Waiver Proposal – Download
May Public Comment Sessions – Visit NYS DOH Website
Care Compass Network’s Written Public Comments – Download