1115 Waiver in New York State: Preparing Your Organization

The New York State 1115 Waiver

The pending approval of the New York State 1115 waiver has provided a further road into care coordination and an increased push towards value based payments. Its primary focus is on minimizing health equity gaps for New Yorkers. 

The $13 billion dollar funding request will establish Health Equity Regional Organizations (HEROs). The goal of HEROs is to coordinate between multiple players in the healthcare system such as hospitals, managed care organizations (MCOs), and community-based providers (CBOs). In addition, HEROs will provide oversight to ensure that all New Yorkers have fair and easy access to healthcare services.  

Another key part of the waiver is addressing gaps of care through Care Coordination Networks. Part of the 1115 waiver in New York is funding and creating Social Determinants of Health Networks (SDHN). SDHNs will work with MCOs and HEROs to build and guide a network of CBOs to address the environmental conditions of New Yorkers to enable individuals to reach their highest levels of health. 

Preparing for the New York 1115 Waiver

The waiver is in the process of being finalized and will change as it gets implemented. This presents a challenge for any preparation efforts – how can a human service organization prepare for the final rollout of the implementation when it hasn’t been finalized? 

It will take time and more data points to fully prepare for the waiver. Our research has indicated that there are several key factors that will to come into play and there are actions organizations can take to prepare.

• Be data-sharing ready. There will be limited HEROs and SDHNs as part of this waiver. Currently, there will be nine (9) HEROs and SDHNs regions across the state, with New York City being subdivided into multiple regions. The total number and the exact regions could change, but regardless, not every organization that applies to be a HERO will be designated as one. One way an organization can gain a competitive advantage in the application process is to demonstrate an ability to acquire and ingest large amounts of data from a variety of sources. Being able to merge their data with national, state and local data will be critical for the waiver. Similarly, SDHNs will need such capabilities. Therefore, organizations who want to become SDHNs should have strong CBO relationships already in place. This should include the ability to securely share data, an understanding of how the data will be used, as well as clear data definitions among the network. All of this will ultimately support network-wide outcomes. 
• Be value-based payment ready. There has been a lot of discussion on the exact role of HEROs and SDHNs, however, over 50% of the funding is directed towards increasing value-based payments (VBPs). VBPs will impact all human service organizations across New York and will push CBOs to achieve better data quality, communicate more effectively about their data, and understand how their outcomes impact their billing. 
• Be technology ready. The 1115 waiver in New York will further push organizations to document services in an electronic case management or EHR system, like Foothold. Even if you are a small organization and doing work on paper there may be a requirement to use different systems to be able to track referrals, assessments, and potentially even documentation. The technology requirements are not currently clear, what is very clear, is the importance of getting data at multiple levels. Even if you are currently using such a system, now is a good time to evaluate its data incorporating and data sharing capabilities. 
• Develop network relationships. Get involved with your local regions and start communicating interest in being part of the waiver. Talk to other providers and entities to find out how they are (or are not) participating in the waiver. This includes not only other CBOs, but also MCOs, local health authorities, hospitals, etc. In addition, while SDHNs might be the first wave, there also will be several other VBP lead entities that could surface. There will be multiple opportunities to be part of a variety of networks.

How Foothold is Preparing for the 1115 Waiver

We are expanding our position to  provide the most secure, modern data structure with information sharing capabilities needed to make the waiver and other coordination efforts a success. This will involve enhancing our referral management as well as an increased level of flexibility. These advancements, along with our continued development of advanced reporting and interoperability, will provide the data infrastructure needed to support this initiative and future objectives that may arise.

Referral management will be key to enabling coordination efforts happening at the CBO level. We want to pull that information alongside service information. Our position is that providing case management and EHR solutions will enable access to service-level data that will allow leaders in the human services space to better assess risk stratification. This will achieve more effective, equitable outcomes for individuals with the greatest need. Leaning solely on referral data will not paint a complete picture of the needs of such populations.

We are also continuing to expand flexibility within our systems. This includes initiatives to make our Care Coordination platform, FCM, deliver greater value to programs outside of the New York State Health Home program. In addition, our case management and EHR (AWARDS) will provide the flexibility to close any of the technology gaps that a CBO or larger network might have a need for. By improving the flexibility and ease of use of both systems, we will increase our likelihood of being able to quickly and effectively adapt to unanticipated changes. 

We see the NYS 1115 waiver as an opportunity for all providers to delve deeper into the healthcare landscape. In addition, the waiver could be a model for other states in the country to follow. We believe this waiver will truly expand the way all New Yorkers are able to access and receive healthcare and supportive services.