WNYHA Waiver Comment Memo

 

1876 Niagara Falls Boulevard Tonawanda, NY 14150 (716) 695-0843 / FAX (716) 695-0073 www.wnyha.com John E. Bartimole, President

	PUBLIC COMMENT Memorandum

Submitted: April 29, 2014

TO:      New York State Office of Medicaid Services, DSRIP Team

RE:      -     MRT Waiver Amendment/Delivery System Reform Incentive Payment Special Terms and

Conditions (STCs); and

-          Interim Access Assurance Fund (IAAF) 

The Western New York Healthcare Association applauds the New York State Department of Health for its herculean efforts to obtain $8 billion in Medicaid Waiver funding for New York State.  Indeed, these dollars, if used correctly, will transform the delivery of healthcare to millions of New Yorkers.

That said, we are concerned that the diverse nature of the state may bring with it inherent risks in the awarding of funding.  Indeed, Western New York—along with other areas of the state—lacks the population (and Medicaid population) density of other regions and also has more limited opportunities for collaboration.

Of particular importance is the need for the DOH to acknowledge that sole community hospitals and rural hospitals, while they may not have the aggregate Medicaid populations of their big-city counterparts, are vital to their communities and Waiver funding is integral to their efforts to collaborate and to transform healthcare in their communities, which is the overarching goal of the Waiver dollars.  Again, we applaud the Department’s willingness to acknowledge that special circumstances exist throughout the state and its willingness to work with our rural and sole community providers to assist them with qualifying to be part of

the Delivery System Reform Incentive Payment and Interim Access Assurance Fund under exception clauses.

Such hospitals are the gateway to healthcare for many rural residents, and if they are overlooked in the awarding of funds, that gateway—often, hospital clinics are the sole or the major provider of primary care—may be closed.

Similarly, the hospitals in cities such as Buffalo and Rochester are vital not only to their own populations, but as irreplaceable sources of specialty and tertiary care for citizens in surrounding communities.  Their importance in the healthcare equation is incalculable.

SUMMARY

These Medicaid Waiver dollars must be used to raise the quality of healthcare for all New Yorkers, regardless of geographic location.  We urge the Department of Health to keep that sacred responsibility in sharp focus as this important process continues.