HANYS Submits Comments on DOH’s Revised Dual-Eligible Demonstration Plan
HANYS submitted comments this week to the Department of Health (DOH) regarding the state’s revised proposal for integrating care for individuals who are eligible for both Medicare and Medicaid (dual eligibles). Based on input from HANYS and other organizations, the revised proposal contains improvements including an option for Health Homes to participate in a managed fee-for-service option. However, HANYS recommended that participation in the managed fee-for-service option not be limited just to Health Homes, and that Primary Care Medical Homes and other care management arrangements should also be able to participate.
HANYS is urging the state to allow flexibility for providers, payers, and practitioners to determine the best way to integrate care at the local level for dual eligibles. Specifically, HANYS’ comments to DOH have focused on:
- care coordination and primary care capacity;
- financing models and risk sharing;
- managed fee-for-service model;
- shared savings;
- interaction with other delivery system reforms;
- Medicare payment policies;
- network adequacy and access;
- quality components;
- supplemental benefits/services; and
- the relationship to the Medicaid global spending cap.