Implementing New York’s DSRIP Program Implications for Medicaid Payment and Delivery System Reform Deborah Bachrach, William Bernstein, Jared Augenstein, Mindy Lipson, and Reni Ellis April 2016 The Commonwealth Fund, among the first private foundations started by a woman philanthropist—Anna M. Harkness—was established in 1918 with the broad charge to enhance the common good. The mission of The Commonwealth Fund is to promote a high-performing health care system that achieves better access, improved quality, and greater efficiency, particularly for society’s most vulnerable, including low-income people, the uninsured, minority Americans, young children, and elderly adults. The Fund carries out this mandate by supporting independent research on health care issues and making grants to improve health care practice and policy. An international program in health policy is designed to stimulate innovative policies and practices in the United States and other industrialized countries. The COMMONWEALTH FUND Implementing New York’s DSRIP Program: Implications for Medicaid Payment and Delivery System Reform Deborah Bachrach, William Bernstein, Jared Augenstein, Mindy Lipson, and Reni Ellis APRIL 2016 ABSTRACT Medicaid is the largest health care payer in virtually every state. States are increasingly leveraging that position to drive payment and delivery system reform efforts. One powerful tool to enable transformation is Medicaid’s Delivery System Reform Incentive Payment (DSRIP) program. New York is implementing the largest and most ambitious program to date, a five-year, $8.25 billion effort aimed at improving the way care is paid for and delivered to Medicaid beneficiaries and ultimately all state residents. Through stakeholder interviews, this report examines New York’s experience implementing its DSRIP waiver, focusing on emerging issues in areas such as governance, data-sharing and analytics, social determinants of health, and value-based payments. The Centers for Medicare and Medicaid Services and other states can use New York’s early experiences to inform their efforts in designing, planning for, and implementing Medicaid-led transformation efforts. Support for this research was provided by The Commonwealth Fund. The views presented here are those of the authors and not necessarily those of The Commonwealth Fund or its directors, officers, or staff. To learn more about new publications when they become available, visit the Fund’s website and register to receive email alerts. Commonwealth Fund pub. 1871. CONTENTS ABOUT THE AUTHORS 5 NEW YORK’S DSRIP PROGRAM AT A GLANCE 6 INTRODUCTION7 ORGANIZATION, GOVERNANCE, AND MARKET TRANSFORMATION 10 CARE MODEL AND SOCIAL DETERMINANTS OF HEALTH 13 DATA-SHARING AND ANALYTICS 16 MEASUREMENT AND ACCOUNTABILITY 17 VALUE-BASED PAYMENT ARRANGEMENTS AND SUSTAINABILITY 18 CONCLUSION22 NOTES23 APPENDIX A. THOUGHT LEADERS AND STAKEHOLDERS INTERVIEWED25 APPENDIX B. ATTRIBUTION AND VALUATION BY PERFORMING PROVIDER SYSTEM26 APPENDIX C. PERFORMING PROVIDER SYSTEM BY COUNTY28 APPENDIX D. PERFORMING PROVIDER SYSTEM PROJECT MENU31 LIST OF EXHIBITS EXHIBIT 1 DISTRIBUTION OF NEW YORK’S 1115 WAIVER FUNDS EXHIBIT 2 KEY DSRIP DATES EXHIBIT 3 NEW YORK’S DSRIP: THE BASICS EXHIBIT 4 PERFORMING PROVIDER SYSTEM ATTRIBUTION METHODOLOGY EXHIBIT 5 SHIFT FROM PAY-FOR-REPORTING TO PAY-FOR-PERFORMANCE EXHIBIT 6 KEY VALUE-BASED PAYMENT DATES IN DSRIP TIMELINE EXHIBIT 7 VALUE-BASED PAYMENT LEVEL REQUIREMENTS 4 Implementing New York’s DSRIP Program: Implications for Medicaid Payment and Delivery System Reform ABOUT THE AUTHORS Deborah Bachrach, J.D., is a partner at Manatt Health, the multidisciplinary legal, policy, and strategic business advi- sory health care division of Manatt, Phelps & Phillips, LLP. Ms. Bachrach has more than 25 years of experience in health policy and financing in both the public and private sectors and an extensive background in Medicaid policy and health care reform. She works with states, providers, plans, and foundations in implementing federal health reform and Medicaid payment and delivery system reforms. Most recently, Ms. Bachrach was Medicaid director and deputy com- missioner of health for the New York State Department of Health, Office of Health Insurance Programs. She has previ- ously served as vice president for external affairs at St. Luke’s-Roosevelt Hospital Center and as chief assistant attor- ney general and chief of the Civil Rights Bureau in the Office of the New York State Attorney General. Ms. Bachrach received her J.D. from New York University School of Law. William Bernstein, J.D., is a partner at Manatt Health, the multidisciplinary legal, policy, and strategic business advi- sory health care division of Manatt, Phelps & Phillips, LLP. His practice concentrates on providing strategic, business and legal advice to clients in the health care industry, including provider organizations, managed care companies, emerging companies, and financial institutions. He has led engagements to create new business models for the organi- zation and payment of health services, developed plans for the broad use of health information technology to support new care delivery systems and counseled numerous states on implementation issues resulting from health reform. Mr. Bernstein began his health care career working for the U.S. Department of Health, Education, and Welfare. He also served as a law clerk to the Honorable Raymond J. Pettine, U.S. District Court of Rhode Island. He received his J.D. from New York University School of Law and his M.A. from Brown University. Jared Augenstein, M.P.H., M.A., is a manager at Manatt Health, the multidisciplinary legal, policy, and strategic busi- ness advisory health care division of Manatt, Phelps & Phillips, LLP. He provides project management, policy analysis, startup business planning, and strategic business services to health care providers, startups, payers, pharmaceutical manufacturers, and other health care organizations. Mr. Augenstein’s primary areas of focus are advising public- and private-sector clients on delivery system transformation, population health, digital health, international and global health, federal and state health policy trends, and provider markets. Mr. Augenstein received his M.P.H. and M.A. from Yale University. Mindy Lipson, M.P.H., is a manager at Manatt Health, the multidisciplinary legal, policy, and strategic business advisory health care division of Manatt, Phelps & Phillips, LLP. She provides research, analysis, project management, and strate- gic business services to state government agencies, health care providers, foundations, and other health care organiza- tions on a broad range of issues. Ms. Lipson’s work focuses on Medicaid reform, health care delivery transformation, population health management, and health information technology and exchange. Prior to joining Manatt, Ms. Lipson was a health research analyst at Mathematica Policy Research, where she conducted quantitative and qualitative data analysis on a wide array of topics, including state health policy, public health programs, Medicare, and Medicaid. Ms. Lipson received her M.P.H. from Columbia University’s Mailman School of Public Health. Reni Ellis, M.P.H., is a senior analyst at Manatt Health, the multidisciplinary legal, policy, and strategic business advi- sory health care division of Manatt, Phelps & Phillips, LLP. She provides research, analytical, and project management support to health care stakeholders across a broad range of areas, including payment and delivery system transforma- tion, Medicaid policy and innovation, health reform implementation, health IT, and pharmaceutical market access, cov- erage, and reimbursement. Ms. Ellis received her M.P.H. from Columbia University’s Mailman School of Public Health. Editorial support was provided by Deborah Lorber. www.commonwealthfund.org 5 At a Glance New York’s Delivery System Reform Incentive Payment (DSRIP) Program What is it? to reduce avoidable hospital use by 25% in five years An $8.25 billion Medicaid-funded program designed by changing the way health care is paid for and delivered. How will that goal be met? based on the value of care rather than the number The state hopes that within five years programs will make at least 80% or type of services delivered. of Medicaid managed care payments to health care providers Will the changes be sustainable? Twenty-five of these networks are launching projects Across the state, Medicaid providers and community-based organizations to improve health outcomes for their patient populations, have formed integrated delivery networks or Performing Provider Systems. enhance disease management programs for chronic conditions, and reform the way providers are paid. Source: D. Bachrach, W. Bernstein, J. Augenstein et al., Implementing New York’s DSRIP Program: Implications for Medicaid Payment and Delivery System Reform (New York: The Commonwealth Fund, April 2016). 6 Implementing New York’s DSRIP Program: Implications for Medicaid Payment and Delivery System Reform Implementing New York’s DSRIP Program: Implications for Medicaid Payment and Delivery System Reform INTRODUCTION With the implementation of the Affordable Care Act, Medicaid has become the largest insurer in the United States, covering almost 25 percent of all Americans.1 State Medicaid agencies are leveraging Medicaid’s purchasing power to drive reform of the delivery system to benefit Medicaid patients and ultimately all patients. One powerful tool available to states is the Delivery System Reform Incentive Payment (DSRIP) program authorized under Section 1115 of the Social Security Act (i.e., the law that authorizes Medicaid). To secure DSRIP funds, states must articu- late a clear vision and plan for reforming their payment and delivery models, integrating care across providers and settings, and advancing the “Triple Aim” of better care, better health, and reduced costs. In April 2014, the Centers for Medicare and Medicaid Services (CMS) approved New York’s $8 billion Medicaid Redesign Team waiver amendment. Of the waiver funds, $6.42 billion are designated for DSRIP (Exhibit 1).2 Aside from this, CMS and the state have allocated an additional $1.83 billion to DSRIP, bringing total DSRIP funds to $8.25 billion.3 In addition, the state is funding a $1.5 billion Capital Restructuring Financing Program to “help strengthen and promote access to essential health services.”4 Seven other states (Alabama, California, Kansas, Massachusetts, New Hampshire, New Jersey, and Texas) also are implementing DSRIP initiatives. Additional states are in negotiations with CMS regarding approval of a DSRIP waiver or have expressed interest in pursuing a DSRIP program. The design and planning of these new programs will be shaped by the experiences of the early implementers. New York’s DSRIP began in April 2014 and will continue through March 31, 2020 (Exhibit 2). The goal of New York’s DSRIP is to “reduce avoidable hospital use by 25 percent through transforming the New York State health care system into a financially viable, high performing system.”5 At the outset, New York required Medicaid providers and community-based orga- nizations to form integrated delivery networks, referred to as Performing Provider Systems (PPSs) as a condition of receiving DSRIP funding. Today, 25 PPSs are implementing a range of projects to build care management and It is of compelling public population health management infrastructure, enhance disease management importance that the state programs for targeted chronic conditions, and improve population health. conduct a fundamental Payment reform is a central component of the New York DSRIP. To ensure restructuring of its Medicaid that its investments in delivery reforms are sustained in the long term, New program to achieve measurable York is requiring that by the end of the five-year DSRIP waiver at least 80 improvement in health percent of payments between Medicaid managed care plans and providers outcomes, sustainable cost use value-based methodologies. control, and a more efficient CMS officials have been clear that New York’s waiver is the new administrative structure. baseline for states pursuing DSRIP initiatives (Exhibit 3). This fact, com- bined with the magnitude of change contemplated in New York, has grabbed New York Governor the attention of Medicaid stakeholders across the country. Andrew Cuomo www.commonwealthfund.org 7 Exhibit  1 Distribution  of  New  York’s  1115  Waiver  Funds $6.42  billion $1.08  billion DSRIP  program  funding Medicaid  redesign  funding Planning  grants Health  home  development DSRIP  funding Long-­‐term  care  services Administrative  costs Total   Home-­‐ and  community-­‐based   services waiver  funds: $8  billion $500  million Interim  Access  Assurance  Fund Time-­‐limited  funding   for  safety-­‐net  providers Note:  The  f ederal  Centers  f or  Medicare  and  Medicaid  Services  and  the  state  allocated  an  billion to DSRIP, bringing total DSRIP funds to $8.25 billion. Note: The federal Centers for Medicare and Medicaid Services and the state allocated an additional $1.83 a dditional  $1.83  billion  to  DSRIP,   bringing  total  DSRIP   funds  to  also is funding a $1.5 billion Capitals  f unding  a  $Financing Program for estructuring  F inancing  Program  f or  DSRIP.   The state $8.25  billion.  The  state  also  i Restructuring 1.5  billion  Capital  RDSRIP. Sources:  Centers   or  Medicare  and  M Services, ervices,  New  York   Plan Special Terms Special  Terms  and   31, 2016; New York State Department of Health, Sources: Centers for fMedicare and Medicaidedicaid  SNew York Partnership Partnership  Plan  and Conditions, MarchConditions,  March  31,  2016;  N ew  York  State   Final DSRIP Valuation Overview, June 2015; and New York State Department of Health, Capital Restructuring Financing Program, April 2015. Department  of  Health,  F inal  DSRIP   Valuation  Overview,  June  2015;  and  New  York  State  Department   of  Health,  Capital  Restructuring  F inancing   Program.   Exhibit  2 Key  DSRIP  Dates Year  0 Year  1 Year  2 Year  3 Year  4 Year  5 April  2 014– April  2 015– April  2 016– April  2 017– April  2 018– April  2 019– March  2 015 March  2 016 March  2 017 March  2 018 March  2 019 March  2 020 April   2014: April   2015:   Payments   By  year  end:   By  year  end:   CMS  approves   DSRIP   begin  to  shift  from   Primary  care   80%–90%  of   Medicaid  R edesign   implementation   pay-­‐for-­‐reporting  to   providers  m ust   managed  care   Team  w aiver   period   begins pay-­‐for-­‐performance have  achieved   payments  to   amendment;  DSRIP   NCQA  2014  Level  3   providers  w ill  be   Year  0  begins PCMH   recognition   paid  through  value-­‐ or  have  m et  state   based  arrangements December  2014:   criteria  for   PPS  applications  due Advanced   Primary   March   31,  2020:   Care  m odel DSRIP  program  ends Sources:  New  York  State  Department   of  HDSRIP Timelines,imelines,  and New York nd  New  York  State  Department  Frequently Asked Questions (FAQs),sked   Sources: New York State Department of Health, ealth,   DSRIP  T Jan. 2016; Jan.  2016;  a State Department of Health, DSRIP of  Health,  DSRIP  F requently  A Aug. 2015. Questions  ( FAQs),  Aug.  2015. 8 Implementing New York’s DSRIP Program: Implications for Medicaid Payment and Delivery System Reform Exhibit 3 New York’s DSRIP: The Basics DSRIP feature The New York approach Goals and timeline New York’s DSRIP initiative aims to “reduce avoidable hospital use by 25% through transforming the New York State health care system into a financially viable, high-performing system.”a New York’s DSRIP began in April 2014 with a planning year and will continue through March 31, 2020. Throughout DSRIP, Performing Provider Systems (PPSs) must meet major milestones. For example, by the end of year 3 of implementation, all participating primary care providers must achieve either NCQA 2014 Level 3 patient-centered medical home recognition or the state’s Advanced Primary Care model criteria. Organization New York organized its DSRIP initiative by selecting lead entities through an application process to create PPSs, which are networks of providers and community-based organizations (CBOs) led by a safety-net provider, most frequently a hospital. PPS participating organizations work together, under the lead entity, to implement DSRIP projects, including initiatives to clinically and financially integrate systems of care. Governance PPSs must have formalized governance structures to oversee the planning and implementation of DSRIP projects, including program planning, patient engagement strategies, administration of funds flow, design and use of information technology, and reporting to the state. Care model(s) PPSs were required to select between five and 11 clinical projects to implement from a menu of 44 projects curated by the state, in consultation with CMS. The range of projects addresses system transformation, clinical improvement, and population health. Projects are based in hospital, primary care, behavioral health, skilled nursing, and other home- and community-based settings. Data-sharing and New York has committed to building the Medicaid Analytics Performance Portal, which houses analytics performance dashboards. The portal will act as a data warehouse and serve as an electronic care planning tool. The state also has committed to sharing Medicaid claims information with PPSs and has required that PPSs ensure that DSRIP-eligible providers be connected to a qualified regional health information organization to promote clinical data-sharing and access to data for treatment purposes. Measurement and New York has imposed a rigorous accountability structure on PPSs. PPSs are responsible for accountability reporting to the state a robust set of process metrics and are accountable for meeting performance metrics, such as reductions in potentially avoidable emergency room visits, potentially avoidable readmissions, and Healthcare Effectiveness Data and Information Set (HEDIS) metrics. The state reports quarterly to CMS, and if milestones are not achieved, CMS will reduce New York’s total DSRIP funding. Funds flow Each PPS has a maximum valuation, defined as the maximum amount of funding it can receive over the five years of DSRIP, based on factors designed to assess the scope and complexity of the PPSs’ undertakings. DSRIP funding flows from the state to PPS lead entities, which are then responsible for distributing the funds to PPS partners, subject to approval by PPS governing bodies. DSRIP payments to PPSs are distinct from the state’s capitation payments to managed care plans. All funds that flow to PPS participating organizations must be reported to the state on a quarterly basis. No more than 5 percent of total PPS funding may flow from a PPS to non-safety-net providers and CBOs. Value-based New York has issued a value-based payment roadmap, which outlines a five-year plan for achieving payment comprehensive payment reform, including a shift to 80 percent to 90 percent value-based arrangements and payments through Medicaid managed care plans by the end of DSRIP. sustainability New York State Department of Health, New York State Delivery System Reform Incentive Payment Program Project Toolkit, Oct. 2014. a www.commonwealthfund.org 9 This report examines New York’s experience implementing its DSRIP waiver to identify emerging issues enabling or impeding Medicaid transformation. Findings are informed by two rounds of interviews: the first with federal and state officials and thought leaders from national health care In New York, DSRIP is one of a organizations, and the second with New York stakeholders involved in on- series of efforts to transform the-ground implementation efforts, including leaders from provider entities, the delivery system. New York health care trade organizations, and health plans. (See Appendix A for a full is also implementing a list of individuals interviewed.) $99.9 million Center for This report focuses on five areas that have broad implications for Medicare and Medicaid stakeholders pursuing Medicaid-driven delivery system reform, with or Innovation State Innovation without a DSRIP waiver: organization, governance and market transforma- Models grant, a statewide tion; care model and social determinants of health; data-sharing and ana- Medicaid Redesign initiative, lytics; measurement and accountability; and value-based payment (VBP) and a Medicaid Health arrangements and sustainability. Across each of these topics, we describe the Home program. New York approach, assess the early successes and challenges, and identify how New York’s experiences can influence new state payment and delivery system reform initiatives. ORGANIZATION, GOVERNANCE, AND MARKET TRANSFORMATION Why It Matters One issue facing states is determining the entities to be entrusted with and held accountable for achieving the qual- ity and cost-saving goals associated with Medicaid transformation. To implement a DSRIP program, a state must define “lead entities,” which are the entities eligible to lead the transformation and receive and distribute funds. While states establish the overarching rules, the lead entities responsible for project implementation and dispensing the DSRIP funds play a central role in shaping transformation, including bringing together provider organizations and community-based organizations (CBOs), establishing the parameters of these new partnerships, and setting priorities. Examining the opportunities and challenges faced by DSRIP lead entities can provide insight into the type of collab- orative partnerships that can result in Medicaid redesign efforts that support high-performing health care systems. The New York Approach In New York, lead entities were defined as major public hospitals and other safety-net providers. CMS and New York policymakers viewed hospital leadership as pivotal to DSRIP’s success, given the size and complexity of the undertaking and the central role of hospitals in New York’s Medicaid delivery system. As one state official summed Many observers noted that the complexity of the application process and the number of economic and programmatic requirements placed on applicants created significant hurdles to serving as a lead entity. Observers also noted the state sought to pair together stronger institutions with weaker ones, and to compel, where possible, market consolidation in the PPSs as a means of promoting the development of stronger and more integrated systems of care. 10 Implementing New York’s DSRIP Program: Implications for Medicaid Payment and Delivery System Reform up: to conduct the amount of transformational work required by DSRIP, organizations serving as lead entities must have financial strength, leadership ability, and access to resources. In the New York health care system, the institu- tions with the strongest platforms to lead complex change initiatives tend to be hospitals. As part of the DSRIP application process, lead entity applicants were required to demonstrate financial viability, which involved passing several stress tests, and the ability to build a PPS by bringing together providers and CBOs to implement DSRIP projects and develop a partnership to enter into valued-based contracting arrange- ments with Medicaid managed care plans. Initially, 88 organizations submitted letters of intent to be a lead entity. The state facilitated a process to consolidate these organizations into fewer PPSs, and 25 organizations received final approval to serve as a lead entity: 23 hospitals, one physician group (in partnership with a hospital), and one feder- ally qualified health center (FQHC).6 The state developed an attribution methodology to ensure that each Medicaid beneficiary was assigned to only one PPS, using geography, utilization data, and patient loyalty trends (Exhibit 4). In forming their PPSs, the lead entities were mindful of the state’s intention to allocate DSRIP funds based on the number of lives attributed to each PPS. They sought to develop broad provider networks generating the largest possible number of attributed lives. (See Appendix B for attribution and valuation by PPS.) PPSs are composed of diverse sets of provider organi- zations and CBOs. PPS partner networks range from several hundred to over 5,000 partners.7 Because of differences in health care markets across state regions, PPSs vary in their position. In some regions, a sole PPS encompasses a large group of competing provider organizations and CBOs. In others, providers and CBOs have signed up with multiple PPSs, resulting in overlapping PPS networks. (See Appendix C for the geographic distribution of PPSs.) Exhibit  4 Performing  Provider  System  Attribution  Methodology New  York  Medicaid  Beneficiaries State  ran  attribution  algorithm1 Nonutilizing,   low-­‐utilizing,   and  uninsured   1 populations2 Attributed  to  local  PPS  undertaking  “Project  11”3 Beneficiaries  with  developmental  disabilities,   2 receiving  long-­‐term  care  services,   or  with  a   Attributed  to  PPSs   based  on  a  loyalty  algorithm behavioral  health  condition Attributed  to  PPSs   based  on  a  loyalty  algorithm   3 All  other  beneficiaries incorporating  health  home  affiliation,   primary  care   provider  connectivity,   and  other  utilization Note:  This  exhibit  describes  the  process  attribution for valuation, which is “the highest possible possible  financial   allocation  receivecfor their plan over thepduration ofhe   Note: This exhibit describes the process for for  attribution  for  valuation,  w hich  is  “ the  h ighest   financial allocation a PPS can a  PPS   an  receive  for  t heir   lan  over  t duration  of  t heir  inarticipation  in  t he  DSRIP  program.”  The  state  distinguishes  between  attribution  for  valuation  apurpose of performance. urpose  of  performance. their participation p the DSRIP program.” The state distinguishes between attribution for valuation and attribution for the nd  attribution  for  t he  p 1 1 If a PPS is the only one inin  a  c ounty,  its  attribution  includes  all  beneficiaries   receiving  a  plurality  o f  services  in  that  c ounty. If  a  P PS  is  the  only  one   a county, its attribution includes all beneficiaries receiving a plurality of services in that county. 2 Nonutilizing members  are  defined  as  enrolled  in  Medicaid  but  h ave  not  u sed  services  in  a  given  year.  L ow-­‐u tilizing  members  are  defined  as  utilizing   three  o r   2 Nonutilizing members are defined as enrolled in Medicaid but have not used services in a given year. Low-utilizing members are defined as utilizing three or fewer services fewer  services  per  year  and  h aving  no  relationship  with  t heir  primary  manager. per year and having no relationship with their primary care provider or care c are  provider  or  c are  m anager. 3 Project  1 1  is  an  o ptional  D SRIP  p roject  t argeted  p rimarily  t oward  p ublic  h ospitals.  The  goal  of  P roject  1 1  is  t o  increase  patient  self-­‐m anagement   and  access  to   3 Project 11 is an optional DSRIP project targeted primarily toward public hospitals. The goal of Project 11 is to increase patient self-management and access to coverage coverage  through  linking  t he  uninsured  population  t o  insurance  coverage  and  t hose  who  are  non-­‐ their primary care providers. through linking the uninsured population to insurance coverage and those who are non- or low-utilizers to or  low-­‐utilizers   to  t heir  primary  c are  providers. Sources:  New  York  State  Department  Health, DSRIP Frequently Asked sked  Questions  (FAQs),   Aug.  2 015;  and  NStateork  State  Department  DSRIP Update: Newpdate:   Sources: New York State Department of of  Health,  D SRIP  Frequently  A Questions (FAQs), Aug. 2015; and New York ew  Y Department of Health, of  Health,  D SRIP  U New  Project,  Attribution  &  Valuation,  Aug.  2 014. Project, Attribution & Valuation, Aug. 2014. www.commonwealthfund.org 11 Providers and CBOs that signed up with multiple PPSs are wrestling with competing priorities from different lead entities and duplicative reporting requirements. Governance structures vary by PPS. As the fiduciary to the state, each lead entity has ultimate authority over how funds are spent and for reporting to the state. A multistakeholder committee structure oversees the devel- opment and approval of key decisions. Some lead entities also have created separately incorporated, wholly owned subsidiaries to house the PPS’s population health capabilities, such as IT, analytics, and care management. How well the PPS governance structure carries out key DSRIP tasks will be a critical indicator of the initiative’s success. PPS governance structures will approve how money is spent and, more important, will decide what sort of contractual obligations are placed on participant organizations in a PPS as a condition of receiving funds. As of early 2016, newly established PPS governing entities are just beginning to make these kinds of decisions. Early Observations and Lessons Learned 1 DSRIP Is a Change Agent for Medicaid Providers The New York DSRIP program is clearly enabling change to the Medicaid delivery system, even if the extent of this change is not yet known. Some DSRIP has galvanized the stakeholders referred to DSRIP as “priming the pump” or as “a down pay- industry to think about ment on transformation.” DSRIP has stimulated planning for the inte- advancing a population health gration of services that have traditionally been siloed; investment in hot infrastructure and accelerating spotting populations requiring the greatest supports; reengineering of care the shift from fee-for-service to management processes; and development of IT and analytics infrastructure population health management. to measure and improve performance over time. While these enterprises are It is making the investment still in early development, it is expected that they will result in greater clini- necessary to make this transition cal and financial integration of provider-led efforts to improve the delivery effective. It has served as both a of health care services. catalyst and an accelerant. PPS leader 2 Long-Term Role of PPSs Is Uncertain There is no consensus as to how PPSs will evolve and fit into the New York landscape post-DSRIP. Their evolution will provide important insights as to what it takes for any delivery system transformation effort, however it is organized or labeled, to succeed. Several commentators noted that transforma- tion is occurring at a far faster pace in communities that are using DSRIP to accelerate preexisting collaborative efforts to clinically and financially integrate care into organized delivery systems, as opposed to where DSRIP served as a wake-up call. Laying the foundation for providers’ transformation to integrated delivery networks is a lengthy process. The DSRIP timetables are challenging for those without preexisting efforts under way. The prevailing view is that most DSRIP PPSs will not survive long term in their current forms, but are transitional vehicles that may give rise to other entities, such as clinically integrated networks or accountable care organizations (ACOs). From this perspective, the partnerships that emerge post-DSRIP will principally be deter- mined by broader market strategies being pursued by large provider organizations, including the merger and consoli- dation activity that has become a staple of the New York marketplace. Many of the partnerships spawned by DSRIP were motivated by a desire to access DSRIP funds, rather than a more deeply considered decision to pursue joint 12 Implementing New York’s DSRIP Program: Implications for Medicaid Payment and Delivery System Reform contracting and collaborative care delivery strategies. In addition, the definition of a safety-net hospital to qualify under DSRIP is broad, and for many PPS hospitals, Medicaid is not their leading line of business.8 For PPSs that are pursuing a joint contracting strategy, a major issue is how the roles and responsibilities of the PPSs complement or overlap with managed care plans’ roles and responsibilities such as network management, data analytics, and care management. As one observer said, “At this point, nobody has articulated a good conceptual framework for how plans and PPSs will coexist in the future state.” 3 PPS Governance Will Evolve Based on Marketplace Realities Lead entities are taking different approaches to defining the scope and nature of obligations placed on participating providers. Many PPSs are still in an early stage of defining their network strategies. But the most mature PPSs view DSRIP as a way to provide monies to build population health infrastructure—care management programs, con- nected health IT capabilities, data analytics, and clinical protocols—that will support clinically and financially inte- grated networks capable of entering into at-risk, value-based payer contracts. What seems to be emerging as a truth in New York—and an important lesson for other states pursuing delivery system transformation—is that though government can fuel change, it cannot legislate its outcome. Some of the “forced marriages” in PPS networks triggered by the DSRIP process will need to be rationalized and adjusted based on trust and common interests that develop between willing collaborators. Absent such evolution, the partner- ships will inevitably dissolve. From a state perspective, it is expected that the governance and organizational struc- tures developed at the start of the DSRIP process will stimulate a transformational process where new, more tightly integrated structures evolve over time as the market matures. Time will tell whether this vision is realized. CARE MODEL AND SOCIAL DETERMINANTS OF HEALTH Why It Matters Delivery system transformation requires providers to fundamentally change their approach to meeting the health needs of the patients and communities they serve. At the heart of the transformation agenda is a shift away from focusing exclusively on treating the sick to working proactively to keep a community healthy. The work to date makes clear that transformation is complex and requires a shift from inpatient to outpatient care, the development of clinically integrated provider networks, changes in the health care workforce, implementation of team-based care models, and partnerships between providers and social services organizations. The New York Approach Having concluded that prior DSRIP programs in California and Texas provided lead entities with too much flexi- bility, CMS required New York to adopt a more focused approach. While the Texas DSRIP gave birth to over 1,500 projects, New York required PPSs to select from a menu of 44 projects or models of care delivery. (See Appendix D for a full list of projects.) The state believed that fewer projects enhanced the likelihood of meeting DSRIP goals, allowed for evaluation of discrete clinical programs, and facilitated state oversight over PPS care model development. New York’s 44 projects fall into three areas: 1) building care management and population health manage- ment infrastructure, including programs that improve care coordination and transitional care, connect care occur- ring in multiple settings, and more systematically engage with patients; 2) clinical programs, focusing on areas such as home-based asthma interventions, primary care and behavioral health integration, cardiovascular care, diabetes www.commonwealthfund.org 13 care, palliative care, and renal care; and 3) population health projects geared toward chronic disease, HIV, maternal and infant health, and mental health and substance abuse prevention. For each project, the state prescribed a gen- eral approach and process and outcomes metrics, but allowed PPSs the flexibility to customize their particular care models. To ensure that projects are implemented according to the state’s vision, New York requires each PPS to achieve “project progress milestones,”—process metrics that assess whether a PPS is adhering to DSRIP require- ments. Examples include establishing a governance structure and implementing clinical projects according to state guidelines. The project progress milestones are distinct from pay-for-reporting and pay-for-performance metrics. Pay-for-reporting and pay-for-performance metrics include select Healthcare Effectiveness Data and Information Set (HEDIS) and Consumer Assessment of Healthcare Providers and Systems (CAHPS) measures. By the end of DSRIP, 85 percent of PPS funding will be based on pay-for-performance (Exhibit 5). New York’s approach emphasizes the impact that delivery system transformation will have on the health care workforce. As part of their applications for funding, PPSs were required to articulate a workforce strategy that would “identify all workforce implications” of DSRIP and “present a plan for how workers will be trained and deployed to meet patient needs in the new delivery system.”9 PPSs are held accountable for meeting milestones related to the hiring, retraining, and redeployment of members of the health care workforce and adhering to a work- force strategy budget. Exhibit  5 Shift  from  Pay-­‐for-­‐Reporting  to  Pay-­‐for-­‐Performance Project  progress  milestones                          Pay-­‐for-­‐reporting                        Pay-­‐for-­‐performance 20% 15% 40% 60% 15% 80% 15% 85% 65% 25% 45% 20% 15% DSRIP  Year  1 DSRIP  Year  2 DSRIP  Year  3 DSRIP  Year  4 DSRIP  Year  5 Note:  As  part  of  a  December   2015  waiver  amendment  request  to  the  f ederal  Centers  f or  Medicare  and  Medicaid  Services,  New  York  is  seeking   Note: As part of a December 2015 waiver amendment request to the federal Centers for Medicare and Medicaid Services, New York is seeking to slightly modify these to  slightly  modify  these  percentages. percentages. Source:   New  York  State  Department  of  Health,  Attachment  I—NY  DSRIP   Program  F unding  and  Mechanics  Protocol,  April  2014. Source: New York State Department of Health, Attachment I—NY DSRIP Program Funding and Mechanics Protocol, April 2014. 14 Implementing New York’s DSRIP Program: Implications for Medicaid Payment and Delivery System Reform Early Observations and Lessons Learned 1 DSRIP Is Generating Investment in Community-Based Care Initiatives There is no question that as a result of the New York DSRIP, PPSs are investing in community-based care initiatives that would not otherwise be funded. As one PPS leader remarked, “DSRIP has catalyzed the transition [from hospital to community-based care] DSRIP is local. It’s about identifying and provided a financial base to cement the transition.” Investments and meeting local needs and include: technical assistance to primary care partners to achieve investing in infrastructure to meet 2014 Level 3 patient-centered medical home (PCMH) recognition; those needs. embedded care management services in primary care settings; expan- sion of community-based asthma programs; and colocation of behav- PPS leader ioral health and primary care services. 2 Sustainability of PPS Investments in New Care Models Is Unclear While PPSs envision that their investments in primary care, care management, and population health management will endure post-DSRIP through value-based payment arrangements, it is unclear how this will work. Stakeholders noted that PPSs have only minimally engaged managed care organizations (MCOs) in their clinical planning efforts, and as a result, may not be aware of duplication between their planned investments and services provided by MCOs. In addition, New York is implementing a health home program to provide care management services to Medicaid beneficiaries with HIV/AIDS, serious mental illness, or multiple chronic conditions.10 PPSs are still clari- fying the role of health homes in DSRIP and are trying to determine how health homes fit into their care manage- ment strategies. As DSRIP progresses, the state, PPSs, and MCOs will need to work together to identify ways to sustain successful programs. 3 Lack of Focus on Social Determinants of Health While PPSs are making substantial investments into strengthening primary care and care management infrastruc- tures, many stakeholders are concerned PPSs are not making similar investments in interventions addressing the social determinants of health. They note that individuals with significant unmet social needs are often driving inap- propriate utilization and high costs. Without sufficiently targeting the social determinants of health, many PPSs are missing an opportunity to reduce costs and improve outcomes. Stakeholders cited a number of reasons for the limited focus on patients’ unmet social needs, starting with the dominance of hospitals in the governance and leadership of PPSs. State timelines required that DSRIP net- works be created quickly. As a result, PPS lead entities incorporated as many organizations as possible into their networks without thoughtfully considering each partner’s role. More fundamentally, there is a large cultural divide between most hospitals and CBOs. Several stakeholders noted that there was not sufficient attention paid to the fact that clinical and CBO communities have little experience working together and they have very different business models, in terms of funding sources, level of accountability, and reporting capabilities. www.commonwealthfund.org 15 Finally, although PPSs express interest in addressing social determinants of health as part of their care mod- els, stakeholders noted there is a mismatch between the perceived need and the dollars available to fund these inter- ventions. New York’s waiver permits only 5 percent of PPS funds to be flowed directly to non-safety-net providers. This category includes clinical providers that do not meet the state’s definition of a safety-net provider and nonclini- cal social support services. As a result, PPSs have had to develop workarounds to flow funds to CBOs that do not provide Medicaid-reimbursable services. DATA-SHARING AND ANALYTICS Why It Matters The successful implementation of new care models and value-based payment structures requires that providers have access to clinical, administrative and financial data that allows targeted identification of at-risk patients and better coordination of care. To create delivery system transformation, states must address a number of significant issues that influence providers’ ability to gain access to, analyze, and use data. Key issues include whether and how to share Medicaid claims information, the requirements that providers use electronic health records, the requirements placed on plans for timely and accurate claims reporting, and requirements for providers to exchange information electronically. The New York Approach New York is taking several approaches to ensure that clinical and claims data are available and used to improve care delivery. First, New York has committed to building the Medicaid Analytics Performance Portal (MAPP) with “the goal of building a 360-degree view of a patient that is not constrained by organizational barriers.”11 MAPP houses performance dashboards, will act as a data warehouse, and will serve as an electronic care planning tool for the health home population.12 New York also has committed to share Medicaid claims information with PPSs. Claims data were supposed to be distributed at the start of the DSRIP implementation period, but distribution was delayed to ensure require- ments were put in place to protect the privacy and security of health information. The state is providing Medicaid patients with a right to opt out of having their Medicaid data shared with the PPS and has also imposed significant security requirements on how PPSs store and distribute data that are shared once the opt-out process is complete. It is expected that claims data for patients who do not opt out will be shared with PPSs in the second quarter of 2016. Some PPSs are working with health plans to directly access plans’ claims feeds, which typically have a shorter lag time than those provided by the state. These arrangements will provide better data to PPSs that are able to establish these relationships, but may result in inconsistent access to claims data for providers across the state. The state is using DSRIP as a lever to promote clinical data exchange among providers. One of the perfor- mance requirements for DSRIP is that eligible providers in a PPS be connected to a regional health information organization (RHIO) that is part of the State Health Information Network of New York (SHIN–NY) by the end of March 2018. In doing so, the state has a goal of promoting SHIN–NY, a statewide health information exchange that has received substantial state investment over the past decade. Under state law, accessing clinical information through the SHIN–NY requires patient consent, a requirement that is more burdensome than federal legal require- ments as set forth in the Health Insurance Portability and Accountability Act (HIPAA). 16 Implementing New York’s DSRIP Program: Implications for Medicaid Payment and Delivery System Reform Early Observations and Lessons Learned 1 Access to Data Is Critical Under DSRIP, the state has recognized the importance of timely access to claims and clinical data to allow providers to better identify at-risk patients and improve coordination of care. Provider stakeholders note that this goal is criti- cal to success, but that privacy requirements under state law impede their access to essential data. One suggestion is to conform state law to federal HIPAA requirements, thereby allowing access to information without consent for purposes of treatment, payment, and operations. The state Value-Based Payment Workgroup’s Regulatory Impact Subcommittee recommends that a new workgroup convene to “address . . . privacy law issues on a scenario by sce- nario basis.”13 2 Analytic Approaches in Early Stage of Development Stakeholders are skeptical as to whether the state’s MAPP tool or the benefits of information exchange through the SHIN–NY will help them achieve their DSRIP performance objectives because of issues of timing and utility. Most stakeholders are taking a wait-and-see attitude, while investing significantly in their own IT and population health capabilities. PPSs’ investments in IT and population health are in an early stage of development. Their ultimate form will have a real impact on providers’ ability to implement more effective care coordination programs. MEASUREMENT AND ACCOUNTABILITY Why It Matters Any state undertaking large-scale delivery system reform must have clear short- and long-term goals and the capac- ity to assess performance against those goals. States that are designing DSRIP initiatives must determine how to ensure accountability without imposing overly burdensome requirements that impede implementation. The New York Approach New York’s DSRIP program has an accountability structure with multiple levels, with substantial reporting require- ments. Organizations participating in DSRIP must report to their PPS, the PPS must report to the state, and the state must report to CMS. Many PPSs require participating organizations to report on how they use their DSRIP funds. In most cases, PPS contracts with participating organizations make receipt of funds contingent upon some form of proof of performance. In addition, the state Office of the Medicaid Inspector General has indicated that recipients should expect to be subject to state audits.14 PPSs have very detailed quarterly reporting obligations to the state on project progress milestones, as well as annual reporting obligations to the state on process and performance measures. Overall, the New York DSRIP involves hundreds of metrics, creating a substantial reporting burden for each PPS. The state is required to report to CMS on a quarterly basis; the terms and conditions governing the rela- tionship between the state and CMS are highly specific. The state’s performance is measured according to four types of milestones: delivery system improvement metrics, performance on DSRIP project and populationwide goals, www.commonwealthfund.org 17 Medicaid spending growth targets, and goals related to transition from fee-for-service payments to value-based payment arrangements. By the final year of DSRIP, $175.6 million of approximately $1 billion in expected DSRIP expenditures are at risk if the state does not achieve certain milestones.15 Early Observations and Lessons Learned 1 Complex Reporting Requirements May Stifle Implementation Efforts While it is broadly acknowledged that it is crucial for DSRIP programs to have rigorous accountability structures, the complexity of New York’s reporting requirements and associated metrics could hinder implementation efforts. For example, under New York’s waiver, each PPS is accountable for between approximately 100 and 330 process and outcome metrics, depending on project selection.16 Provider stakeholders observed that the number of process metrics that PPSs are required to report creates a heavy administrative burden for PPSs, taking focus and time away from project implementation. VALUE-BASED PAYMENT ARRANGEMENTS AND SUSTAINABILITY Why It Matters Value-based payment (VBP) reforms are a key ingredient to motivating and sustaining provider-led initiatives to improve health care service delivery. But it is difficult for states to balance the substantial investment necessary to enable providers to change their business models with the need to control overall Medicaid spending. Achieving value is further complicated by the need to determine how available dollars, along with risk and responsibility for administrative and medical spend- ing, should be distributed among providers and payers. States undertaking Medicaid delivery system reform must simultaneously pursue the develop- [DSRIP is] not about launching ment and implementation of new care models, payment reforms that align 10 or 11 projects, not about provider and payer incentives, and state budget goals. ticking boxes to hit particular requirements, not about The New York Approach moving the needle on As part of its DSRIP initiative, New York developed and received CMS performance measures. approval of a “VBP roadmap,” which outlines a five-year plan for com- It’s about a fundamental prehensive payment reform in New York Medicaid (Exhibit 6). The VBP restructuring towards a system roadmap provides options for MCO and provider contracting structures to that really rewards value. It’s share the savings expected to be generated through the implementation of beginning to sink in with folks new clinical models and population health management capabilities. The that that’s really the endgame state expects that a significant percent of Medicaid beneficiaries will be here, and what they should be in managed care plans by the end of 2018.17 As such, these new contract working towards. models are the linchpin to the sustainability of DSRIP programs. The VBP roadmap is robust and will likely serve as a blueprint for other states con- templating DSRIP waivers. State government official 18 Implementing New York’s DSRIP Program: Implications for Medicaid Payment and Delivery System Reform Exhibit  6 Key  Value-­‐Based  Payment  Dates  in  DSRIP  Timeline Year  0 Year  1 Year  2 Year  3 Year  4 Year  5 April  2 014– April  2 015– April  2 016– April  2 017– April  2 018– April  2 019– March  2 015 March  2 016 March  2 017 March  2 018 March  2 019 March  2 020 April   2014: June   2015:   PPSs  submit   By  year  end:   By  year  end:   By  year  end:   DSRIP  Year  0  begins CMS  approves  S tate   growth  plans   At  least  10%  of  total   At  least  50%  of  total   80%–90%  of  total   Roadmap  for   outlining  the  path   MCO  expenditures   MCO  expenditures   MCO  expenditures   Medicaid  Payment   of  their  network   are  captured   in   are  captured   in   are  captured   in  at   Reform towards  90%  VBP Level  1  VBP   Level  1  VBP   least  Level  1  VBPs arrangements  or   arrangements  or   At  least  35%  of  total   above above   payments  are   At  least  15%  of  total   captured  in  Level  2   payments  are   VBP  arrangements  or   captured  in  Level  2   higher  (fully   VBP  arrangements   capitated  plans) or  higher  (fully   At  least  15%  of  total   capitated  plans) payments  are   captured  in  Level  2   VBP  arrangements  or   higher  ( not  fully   capitated  plans) Note:  MCO  managed carecorganization. Note: MCO = =  managed   are  organization. Source:   New  York  State  Department  of  HA Path Toward Value-Based Payment: New York State RoadmapState  Roadmap  f or  Medicaid  Payment  Reform  2016. Source: New York State Department of Health, ealth,  A  Path  Toward  Value-­‐Based  Payment:  N ew  York   for Medicaid Payment Reform Annual Update, March Annual  U pdate,  March  2016. The VBP roadmap requires that 80 percent to 90 percent of managed care payments to providers use VBP methodologies by the end of the five-year DSRIP waiver. The state anticipates MCOs will contract with provider entities through four types of arrangements: • Total care for the general population: The provider is accountable for the cost and quality of all services received by its attributed population with the exception of special needs populations. • Total care for special needs populations: Providers serving special needs populations, such as people living with HIV/AIDS or developmental disabilities, are held accountable for the cost and quality of care delivered to their attributed members. • Integrated primary care: PCMHs or practices meeting the state’s Advanced Primary Care criteria are accountable for a specified set of primary care, care coordination, and population health management services.18 • Bundles of care: New York is permitting bundles for maternity care and chronic care. The provider is accountable for the costs and quality of services across the care continuum for maternity care and specified chronic conditions, such as asthma, diabetes, and osteoarthritis.19 New York views its approach to VBP as aligned with Medicare reforms, including the shift to Next Generation ACOs, the Bundled Payments for Care Improvement Initiative, and Comprehensive Care for Joint Replacement Payment Model. Across the four types of VBP arrangements, the state has defined four approaches, each corresponding to a higher level of risk for provider (Exhibit 7). www.commonwealthfund.org 19 Exhibit 7 Value-Based Payment Level Requirements VBP options Level 0 VBPa Level 1 VBP Level 2 VBP Level 3 VBPb Total care Fee-for-service FFS with upside-only FFS with risk-sharing Global capitation for general (FFS) with bonus shared savings (when (upside and downside) (with quality-based population and/or withhold quality scores are sufficient) component) based on quality scores Total care for FFS with bonus FFS with upside-only FFS with risk- PMPM capitated subpopulation and/or withhold shared savings based on sharing-based on payment for total care based on quality subpopulation capitation subpopulation for subpopulation scores (when quality scores are capitation (upside and (with quality-based sufficient) downside) component) Integrated FFS (plus PMPM FFS (plus PMPM subsidy) FFS (plus PMPM PMPM capitated primary care subsidy) with with upside-only shared- subsidy) with risk- payment for primary bonus and/or savings based on total cost sharing based on total care services (with withhold based on of care (when quality scores cost of care (upside and quality-based quality scores are sufficient) downside) component) Bundles of care FFS with bonus FFS with upside-only FFS with risk-sharing Prospective bundled and/or withhold shared savings based based on bundle payment (with quality- based on quality on bundle of care (when of care (upside and based component) scores quality scores are sufficient) downside) Note: PMPM = per member per month. a Level 0 is a baseline, and managed care payments at this level will not count toward 80%–90% VBP. b Level 3 feasible only after experience at other levels. Source: New York State Department of Health, A Path Toward Value-Based Payment: New York State Roadmap for Medicaid Payment Reform Annual Update, March 2016. Early Observations and Lessons Learned 1 Ultimate Relationship Between PPSs and MCOs Is Unclear The state has established a general framework governing contractual rela- tionships between MCOs and providers, but defers to MCOs and provid- ers to determine the precise form of those relationships within established guardrails. It is unclear whether providers and payers will be able to agree We’re in a race to get to value- on how to best allocate roles, responsibilities, and the flow of funds, without based reimbursement before increased state intervention. This issue is especially important to resolve, as other funding streams run out. many PPSs are investing significantly in population health infrastructure, the costs of which can be supported only if ultimately paid for through restruc- tured arrangements with MCOs. Some states like Minnesota have imposed PPS leader specific downstream contracting requirements on health plans, including requirements covering required ACO contracting, patient attribution meth- odologies, and shared savings or loss calculations.20 New York has largely left these details to the MCOs and provid- ers to negotiate. 20 Implementing New York’s DSRIP Program: Implications for Medicaid Payment and Delivery System Reform 2 VBP Requirements May Incentivize Provider Consolidation It is also unclear whether providers who joined a PPS to participate in DSRIP also will be willing to participate with the same group of providers in joint managed care contracting arrangements after DSRIP ends. If these pro- viders are willing to participate in joint contracting arrangements, it would require accepting risk as a group of dis- parate providers that may not have access to each other’s performance data. It also may require providers to subject themselves to new governance arrangements that have authority over network participation rules and the distribu- tion of funds. Market participants are just beginning to realize how complex an issue this is for each PPS participating provider, especially because many DSRIP participating providers already have MCO contracts in place and will need to evaluate how their current arrangements would compare to any pro- What we’d be interested in posed new arrangement. purchasing is a functioning Many stakeholders expect DSRIP to lead to the creation of provider- integrated delivery system that governed risk-bearing entities, although significant issues exist as to the really works—where there is ultimate form of those entities, the rules governing network participation, innovation, where providers and the governance structures of such entities. CMS and other states con- get electronic notifications templating Medicaid delivery system transformation will be keen observers seamlessly, and where there of this dynamic, watching to see if the benefits of more highly coordinated, are emergency room diversion provider-led delivery systems will outweigh the costs of consolidation. Many programs, hospital-to-home- MCOs fear that too much provider consolidation could increase providers’ transition programs, and power in negotiating prices, a point echoed in an April 2015 letter issued by innovative ways to reach the Federal Trade Commission (FTC). “FTC staff is concerned that combin- people in the community. ing the DSRIP program with [Certificate of Public Advantage]21 regulations will encourage health care providers to share competitively sensitive informa- Managed care plan tion and engage in joint negotiations with payers in ways that will not yield executive efficiencies or benefit consumers,” the letter stated.22 3 Will Social Services Be Supported in VBP Relationships? While the VBP roadmap envisions that contracts for integrated primary care will include “clear alignments with community-based, home, and social service agencies” it is unclear if and how these services will be supported in practice.23 Social services typically are not reimbursed in fee-for-service relationships with insurers nor are their costs built into the rates paid to MCOs by the state. In addition, insurance payments typically are not included in the revenue streams of social service organizations. While provider entities taking on risk will want their members to receive social service interventions with demonstrable value, the role these providers will play in funding those inter- ventions has yet to be determined. The Social Determinants of Health and CBO Subcommittee of the state’s VBP Workgroup addressed this issue in its February 2016 recommendations: “Providers/provider networks and MCOs should invest in, and the state should provide financial incentives for, ameliorating [social determinants of health] at the community level employing a community participatory process.”24 In relation to payment for social service inter- ventions, one hospital executive noted, “there is magical thinking that if you move to VBP, everything will be taken care of.” www.commonwealthfund.org 21 3 Payment Levels Matter One issue raised by PPS and managed care executives is that shift- You can’t sustain a program on ing payment from fee-for-service to VBP arrangements will not nothing. Post-DSRIP, there is going to solve an underlying economic issue of low reimbursement. To the be some continuing need for support extent that a bundled or global capitation payment is developed for transformation, and we don’t want based on historical fee-for-service rates that may themselves be too the system to stop transforming. low, the bundle will be insufficient to cover required clinical ser- vices, much less investments in care coordination or social services that are envisioned. Trade association leader CONCLUSION Changing how the state pays for services and how providers deliver care is at the heart of New York’s efforts to rede- sign Medicaid. Given the enormity and complexity of this effort, it is hardly surprising that it is a messy process and there is a diversity of perspectives on what is and is not working, as well as what requires re-envisioning. This stage of the process brings to mind President Theodore Roosevelt’s observation that absent great effort, both valiant and flawed, there is never “high achievement.” Extraordinary resources—financial and human—are being devoted in an effort to dramatically improve New York’s health care delivery system. The results will resonate beyond Medicaid and New York, to be watched and studied by all. 22 Implementing New York’s DSRIP Program: Implications for Medicaid Payment and Delivery System Reform NOTES 1 J. Paradise, Medicaid Moving Forward (Kaiser Family Foundation, March 2015). 2 Centers for Medicare and Medicaid Services, New York Partnership Plan Special Terms and Conditions, March 31, 2016. 3 New York State Department of Health, Final DSRIP Valuation Overview, June 2015. 4 New York State Department of Health, Capital Restructuring Financing Program, April 2015. 5 New York State Department of Health, New York State Delivery System Reform Incentive Payment Program Project Toolkit, Oct. 2014. 6 New York State Department of Health, DSRIP Performing Provider Systems (PPS), Jan. 2016. 7 New York State Department of Health, Performing Provider System Network Lists, July 2015. 8 Only state-designated safety-net providers were eligible to serve as lead entities. To be classified as a safety-net pro- vider, a hospital had to meet one of the following criteria: 1) be a public hospital, critical access hospital, or sole com- munity hospital; 2) serve at least 35 percent Medicaid, uninsured, or dual-eligible patients in their outpatient business and at least 30 percent Medicaid, uninsured, or dual-eligible patients in their inpatient business; or 3) serve at least 30 percent of all Medicaid, uninsured, or dual-eligible patients in their service region. Non-hospital-based providers were classified as safety-net providers if 35 percent of their business was composed of Medicaid, uninsured, or dual-eligible patients. Centers for Medicare and Medicaid Services, New York Partnership Plan Special Terms and Conditions, March 31, 2016. 9 Centers for Medicare and Medicaid Services, New York Partnership Plan Special Terms and Conditions, March 31, 2016. 10 New York State Department of Health, Eligibility Criteria for Health Home Services: Chronic Conditions, Sept. 23, 2014. 11 G. Allen and P. Roohan, Letter to PPS and RHIO Executives, RE: Integrating clinical information from the State Health Information Network of New York (SHIN-NY) with Medicaid claims data, July 21, 2015. 12 New York State Department of Health, MAPP 101 Webinar, June 2015. 13 New York State Department of Health VBP Regulatory Impact Subcommittee, Meeting #6 Minutes, Dec. 7, 2015. 14 Office of the Medicaid Inspector General, New York State Department of Health, Frequently Asked Questions by Performing Provider System (PPS) Leads Relative to Compliance Programs, July 15, 2015. 15 Centers for Medicare and Medicaid Services, New York Partnership Plan Special Terms and Conditions, March 31, 2016. In December 2015, New York submitted a waiver amendment request to CMS that would increase the maximum amount of funds at risk to $200 million in the fifth year of DSRIP. 16 New York State Department of Health, DSRIP Measure Specification and Reporting Manual, Feb. 25, 2016; and New York State Department of Health, DSRIP Domain 1 Project Requirements, Milestones, and Metrics, March 20, 2015. 17 New York State Department of Health, Care Management for All, July 24, 2014. 18 New York created the Advanced Primary Care model as part of the New York State Health Innovation Plan. The state defines advanced primary care as “an integrated care delivery and payment model that ties together a service delivery model and reimbursement to promote improved health and health care outcomes that are financially sustainable.” New York State Department of Health, New York State’s Advanced Primary Care Model Frequently Asked Questions, Dec. 2015. 19 New York State Department of Health, A Path Toward Value-Based Payment: New York State Roadmap for Medicaid Payment Reform Annual Update, March 2016. www.commonwealthfund.org 23 20 Minnesota Department of Human Services, Contract for Medical Assistance and MinnesotaCare Medical Care Services: 2016 Families and Children Contract, Jan. 1, 2016. 21 As defined by New York, “a COPA is a document issued by the Department of Health (Department) signifying the approval of a Cooperative Agreement or planning process, subject to certain conditions being satisfied. Parties that have received a COPA are provided state action immunity under federal antitrust laws and immunity from private claims under state antitrust laws and may negotiate, enter into, and conduct business pursuant to, a Cooperative Agreement or a planning process covered by a duly issued Certificate of Public Advantage.” 22 U.S. Federal Trade Commission, Letter to Center for Health Care Policy and Resource Development, Office of Primary Care and Health Systems Management, RE: Certificate of Public Advantage Applications Filed Pursuant to New York Public Health Law, 10 NYCRR, Subpart 83-1, April 22, 2015. 23 New York State Department of Health, A Path Toward Value-Based Payment: New York State Roadmap for Medicaid Payment Reform Annual Update, March 2016. 24 New York State Department of Health, Value-Based Payment: Subcommittee Recommendation Report, Feb. 2016. 24 Implementing New York’s DSRIP Program: Implications for Medicaid Payment and Delivery System Reform Appendix A Thought Leaders and Stakeholders Interviewed National thought leaders Lindsey Browning, Senior Policy Analyst, National Association of Medicaid Directors Sophia Chang, Vice President of Programs, California Health Care Foundation Beth Feldpush, Senior Vice President of Policy and Advocacy, America’s Essential Hospitals Eliot Fishman, Director, State Demonstrations Group, Center for Medicaid and CHIP Services, Centers for Medicare and Medicaid Services Heather Howard, Program Director, State Health Reform Assistance Network, Robert Wood Johnson Foundation Frederick Isasi, Division Director, Health Division, National Governor’s Association Center for Best Practices Kathleen Nolan, Managing Principal, Health Management Associates (Director, State Policy and Programs, National Association of Medicaid Directors at time of interview) Chris Perrone, Director, Improving Access, California Health Care Foundation Trish Riley, Executive Director, National Academy for State Health Policy Matt Salo, Executive Director, National Association of Medicaid Directors Bruce Siegel, President and CEO, America’s Essential Hospitals Hemi Tewarson, Program Director, Health Division, National Governors Association Center for Best Practices New York stakeholders Gregory Allen, Director, Division of Program Development and Management, Office of Health Insurance Programs, New York State Department of Health Gary Belkin, Executive Deputy Commissioner for Mental Health, New York City Department of Health and Mental Hygiene Marc Berg, Principal, Health Care Strategy and Transformation, KPMG LLP USA Deb Blanchard, Director of Patient-Centered Medical Homes, Finger Lakes PPS Peggy Chan, Director, DSRIP, New York State Department of Health Andrea Cohen, Senior Vice President for Program, United Hospital Fund David Cohen, CEO, Central Services Organization, Community Care of Brooklyn; Executive Vice President, Clinical Affairs & Affiliations at Maimonides Medical Center Donna Colonna, CEO, Services for the UnderServed Carla D’Angelo, Senior Vice President of Strategic Business Development, Monroe Plan for Medical Care Diane Ferran, Senior Director, Clinical Quality Improvement Program, Community Health Care Association of New York State Arthur Gianelli, President, Mount Sinai St. Luke’s; President, Mount Sinai PPS Board of Managers Dennis Graziano, President/CEO, Monroe Plan for Medical Care Val Grey, Executive Vice President, Healthcare Association of New York State Beverly Grossman, Senior Policy Director, Community Health Care Association of New York State Jason Helgerson, Medicaid Director, New York State Harold Iselin, Managing Shareholder, Greenberg Traurig, LLP Christina Jenkins, President and CEO, OneCity Health Deborah King, Executive Director, 1199 SEIU Training and Employment Funds Jeffrey Kraut, Senior Vice President, Strategy and Business Informatics, Northwell Health Pamela Mattel, COO, Acacia Network Ann Monroe, President, Health Foundation for Western & Central New York Lisa Perry, Vice President, Quality and Technology Initiatives, Community Health Care Association of New York State John Rugge, CEO, Hudson Headwaters Health Network Chad Shearer, Director, Medicaid Institute, United Hospital Fund Kathleen Shure, Senior Vice President, Health Economics, Finance, and Managed Care, Greater New York Hospital Assn. Carol Tegas, Executive Director of the Finger Lakes PPS Pat Wang, CEO, HealthFirst Dennis Whalen, President, Healthcare Association of New York State Grace Wong, Vice President and CFO of Medicaid Strategy, Northwell Health www.commonwealthfund.org 25 Appendix B Attribution and Valuation by Performing Provider System Performing Provider System Number of attributed Maximum Safety net or PPS lead entity or entities Medicaid membersa valuationb public lead entity? Adirondack Health Institute PPS 143,640 $186,715,496 Safety net Adirondack Health Institute Advocate Community Providers AW Medical Office, PC; New York Community 312,623 $700,038,844 Safety net Preferred Partners; Northwell Health Albany Medical Center Hospital PPS 107,781 $141,430,547 Safety net Albany Medical Center Alliance for Better Health Care 193,150 $250,232,844 Safety net Ellis Hospital Bronx Partners for Healthy Communities 159,201 $384,271,362 Safety net SBH Health System Bronx-Lebanon Hospital Center PPS 70,861 $153,930,779 Safety net Bronx-Lebanon Hospital Center Brooklyn Bridges 74,326 $127,740,537 Safety net NYU Lutheran Medical Center Care Compass Network 186,101 $224,540,274 Safety net United Health Services Hospitals Central New York Care Collaborative Auburn Community Hospital; Faxton St. Luke’s 262,144 $323,029,955 Public Healthcare; St. Joseph’s Hospital Health Care; SUNY Upstate University Hospital Community Care of Brooklyn 212,586 $489,039,450 Safety net Maimonides Medical Center Community Partners of Western NY 43,375 $92,253,402 Safety net Sisters of Charity Hospital Finger Lakes PPS 413,289 $565,448,177 Safety net Rochester Regional Health System; UR Medicine Hudson Valley Collaborative 105,752 $249,071,149 Safety net Montefiore Medical Center Leatherstocking Collaborative Health Partners PPS 62,043 $71,839,379 Safety net Bassett Medical Center Millennium Collaborative Care 309,457 $243,019,729 Public Erie County Medical Center Mount Sinai PPS 136,370 $389,900,648 Safety net Mount Sinai Health System Nassau Queens PPS Nassau University Medical Center, in alliance with 1,030,400 $535,396,603 Public Northwell Health and Catholic Health Services of Long Island New York-Presbysterian/Queens PPS 12,962 $31,776,993 Safety net New York-Presbyterian/Queens New York-Presbyterian PPS 47,293 $97,712,825 Safety net New York-Presbyterian Hospital North Country Initiative 61,994 $78,062,822 Safety net Samaritan Medical Center 26 Implementing New York’s DSRIP Program: Implications for Medicaid Payment and Delivery System Reform Performing Provider System Number of attributed Maximum Safety net or PPS lead entity or entities Medicaid membersa valuationb public lead entity? OneCity Health 2,760,602 $1,215,165,724 Public NYC Health + Hospitals Refuah Community Health Collaborative 26,804 $45,634,589 Safety net Refuah Health Center Staten Island PPS Richmond University Medical Center; Staten Island 180,268 $217,087,986 Safety net University Suffolk Care Collaborative 437,896 $298,562,084 Public SUNY at Stony Brook University Hospital WMCHealth PPS Westchester Medical Center 573,393 $273,923,615 Public a This column reflects each PPS’s attribution for valuation, which is the “number of Medicaid and uninsured lives for use in the calculation of potential performance awards as part of the DSRIP valuation process.” New York State Department of Health, Bringing The Pieces Together: Attribution for Performance, Provider Counts by Service Type & Speed & Scale Templates, Dec. 2014. b The state defines maximum valuation for a PPS as “the highest possible financial allocation a PPS can receive for their plan over the duration of their participation in the DSRIP program.” New York State Department of Health, DSRIP Frequently Asked Questions (FAQs), Aug. 2015. Source: New York State Department of Health, DSRIP Performing Provider Systems by County, Jan. 2016. www.commonwealthfund.org 27 Appendix C Performing Provider System by County County Performing Provider System (PPS lead entity or entities) Upstate 10 PPSs Albany Albany Medical Center Hospital PPS (Albany Medical Center) Alliance for Better Health Care (Ellis Hospital) Allegany Finger Lakes PPS (Rochester Regional Health System/UR Medicine) Millennium Collaborative Care (Erie County Medical Center) Broome Care Compass Network (United Health Services Hospitals) Cattaraugus Millennium Collaborative Care (Erie County Medical Center) Cayuga Central New York Care Collaborative (Auburn Community Hospital/Faxton St. Luke’s Healthcare/ St. Joseph's Hospital Health Care/SUNY Upstate University Hospital) Finger Lakes PPS (Rochester Regional Health System/UR Medicine) Chautauqua Community Partners of Western New York (Sisters of Charity Hospital) Millennium Collaborative Care (Erie County Medical Center) Chemung Care Compass Network (United Health Services Hospitals) Finger Lakes PPS (Rochester Regional Health System/UR Medicine) Chenango Care Compass Network (United Health Services Hospitals) Clinton Adirondack Health Institute PPS (Adirondack Health Institute) Columbia Albany Medical Center Hospital PPS (Albany Medical Center) Cortland Care Compass Network (United Health Services Hospitals) Delaware Care Compass Network (United Health Services Hospitals) Leatherstocking Collaborative Health Partners PPS (Bassett Medical Center) Erie Community Partners of Western New York (Sisters of Charity Hospital) Millennium Collaborative Care (Erie County Medical Center) Essex Adirondack Health Institute PPS (Adirondack Health Institute) Franklin Adirondack Health Institute PPS (Adirondack Health Institute) Fulton Adirondack Health Institute PPS (Adirondack Health Institute) Alliance for Better Health Care (Ellis Hospital) Genesee Finger Lakes PPS (Rochester Regional Health System/UR Medicine) Millennium Collaborative Care (Erie County Medical Center) Greene Albany Medical Center Hospital PPS (Albany Medical Center) Hamilton Adirondack Health Institute PPS (Adirondack Health Institute) Herkimer Leatherstocking Collaborative Health Partners PPS (Bassett Medical Center) Jefferson North Country Initiative (Samaritan Medical Center) Lewis Central New York Care Collaborative (Auburn Community Hospital/Faxton St. Luke’s Healthcare/ St. Joseph's Hospital Health Care/SUNY Upstate University Hospital) North County Initiative (Samaritan Medical Center) Livingston Finger Lakes PPS (Rochester Regional Health System/UR Medicine) Madison Central New York Care Collaborative (Auburn Community Hospital/Faxton St. Luke’s Healthcare/ St. Joseph's Hospital Health Care/SUNY Upstate University Hospital) Leatherstocking Collaborative Health Partners PPS (Bassett Medical Center) Monroe Finger Lakes PPS (Rochester Regional Health System/UR Medicine) Montgomery Alliance for Better Health Care (Ellis Hospital) Niagara Community Partners of Western New York (Sisters of Charity Hospital) Millennium Collaborative Care (Erie County Medical Center) 28 Implementing New York’s DSRIP Program: Implications for Medicaid Payment and Delivery System Reform County Performing Provider System (PPS lead entity or entities) Oneida Central New York Care Collaborative (Auburn Community Hospital/Faxton St. Luke’s Healthcare/ St. Joseph's Hospital Health Care/SUNY Upstate University Hospital) Onondaga Central New York Care Collaborative (Auburn Community Hospital/Faxton St. Luke’s Healthcare/ St. Joseph's Hospital Health Care/SUNY Upstate University Hospital) Ontario Finger Lakes PPS (Rochester Regional Health System/UR Medicine) Orleans Finger Lakes PPS (Rochester Regional Health System/UR Medicine) Millennium Collaborative Care (Erie County Medical Center) Oswego Central New York Care Collaborative (Auburn Community Hospital/Faxton St. Luke’s Healthcare/ St. Joseph's Hospital Health Care/SUNY Upstate University Hospital) Otsego Leatherstocking Collaborative Health Partners PPS (Bassett Medical Center) Rensselaer Alliance for Better Health Care (Ellis Hospital) St. Lawrence Adirondack Health Institute PPS (Adirondack Health Institute) North County Initiative (Samaritan Medical Center) Saratoga Adirondack Health Institute PPS (Adirondack Health Institute) Albany Medical Center Hospital PPS (Albany Medical Center) Alliance for Better Health Care (Ellis Hospital) Schenectady Alliance for Better Health Care (Ellis Hospital) Schoharie Leatherstocking Collaborative Health Partners PPS (Bassett Medical Center) Schuyler Care Compass Network (United Health Services Hospitals) Seneca Finger Lakes PPS (Rochester Regional Health System/UR Medicine) Steuben Care Compass Network (United Health Services Hospitals) Finger Lakes PPS (Rochester Regional Health System/UR Medicine) Tioga Care Compass Network (United Health Services Hospitals) Tompkins Care Compass Network (United Health Services Hospitals) Warren Adirondack Health Institute PPS (Adirondack Health Institute) Albany Medical Center Hospital PPS (Albany Medical Center) Washington Adirondack Health Institute PPS (Adirondack Health Institute) Wayne Finger Lakes PPS (Rochester Regional Health System/UR Medicine) Wyoming Finger Lakes PPS (Rochester Regional Health System/UR Medicine) Millennium Collaborative Care (Erie County Medical Center) Yates Finger Lakes PPS (Rochester Regional Health System/UR Medicine) Hudson Valley 3 PPSs Dutchess Hudson Valley Cooperative (Montefiore Medical Center) WMCHealth PPS (Westchester Medical Center) Orange Hudson Valley Cooperative (Montefiore Medical Center) Refuah Community Health Collaborative (Refuah Health Center) WMCHealth PPS (Westchester Medical Center) Putnam Hudson Valley Cooperative (Montefiore Medical Center) WMCHealth PPS (Westchester Medical Center) Rockland Hudson Valley Cooperative (Montefiore Medical Center) Refuah Community Health Collaborative (Refuah Health Center) WMCHealth PPS (Westchester Medical Center) Sullivan Hudson Valley Cooperative (Montefiore Medical Center) WMCHealth PPS (Westchester Medical Center) Ulster Hudson Valley Cooperative (Montefiore Medical Center) WMCHealth PPS (Westchester Medical Center) Westchester Hudson Valley Cooperative (Montefiore Medical Center) WMCHealth PPS (Westchester Medical Center) www.commonwealthfund.org 29 County Performing Provider System (PPS lead entity or entities) Long Island 2 PPSs Nassau Nassau Queens PPS (Nassau University Medical Center, in alliance with Northwell Health and Catholic Health Services of Long Island) Suffolk Suffolk Care Collaborative (State University of New York at Stony Brook University Hospital) New York City 11 PPSs Bronx Advocate Community Providers (AW Medical Office, PC/New York Community Preferred Partners/ Northwell Health) Bronx-Lebanon Hospital Center PPS (Bronx-Lebanon Hospital Center) Bronx Partners for Healthy Communities (SBH Health System) OneCity Health (NYC Health + Hospitals) Kings Advocate Community Providers (AW Medical Office, PC/New York Community Preferred Partners/ Northwell Health) Brooklyn Bridges (NYU Lutheran Medical Center) Community Care of Brooklyn (Maimonides Medical Center) Mount Sinai PPS (Mount Sinai Health System) OneCity Health (NYC Health + Hospitals) New York Advocate Community Providers (AW Medical Office, PC/New York Community Preferred Partners/ Northwell Health) New York-Presbyterian PPS (New York-Presbyterian Hospital) Mount Sinai PPS (Mount Sinai Health System) OneCity Health (NYC Health + Hospitals) Queens Advocate Community Providers (AW Medical Office, PC/New York Community Preferred Partners/ Northwell Health) Community Care of Brooklyn (Maimonides Medical Center) Mount Sinai PPS (Mount Sinai Health System) Nassau Queens PPS (Nassau University Medical Center, in alliance with Northwell Health and Catholic Health Services of Long Island) New York-Presbyterian/Queens PPS (New York-Presbyterian/Queens) OneCity Health (NYC Health + Hospitals) Richmond Staten Island PPS (Richmond University Medical Center/Staten Island University) Source: New York State Department of Health, DSRIP Performing Provider Systems by County, Jan. 2016. 30 Implementing New York’s DSRIP Program: Implications for Medicaid Payment and Delivery System Reform Appendix D Performing Provider System Project Menu Project number Project name Domain 2. System transformation projects A. Create integrated delivery systems 2.a.i Create integrated delivery systems that are focused on evidence-based medicine and population health management 2.a.ii Increase certification of primary care practitioners with PCMH certification and/or Advanced Primary Care models (as developed under the NYS Health Innovation Plan (SHIP)) 2.a.iii Health home at-risk intervention program: proactive management of higher risk patients not currently eligible for health homes through access to high quality primary care and support services 2.a.iv Create a medical village using existing hospital infrastructure 2.a.v Create a medical village/alternative housing using existing nursing home infrastructure B. Implementation of care coordination and transitional care programs 2.b.i Ambulatory intensive care units 2.b.ii Development of co-located primary care services in the emergency department (ED) 2.b.iii Emergency department care triage for at-risk populations 2.b.iv Care transitions intervention model to reduce 30-day readmissions for chronic health conditions 2.b.v Care transitions intervention for skilled nursing facility (SNF) residents 2.b.vi Transitional supportive housing services 2.b.vii Implementing the INTERACT project (inpatient transfer avoidance program for SNF) 2.b.viii Hospital-home care collaboration solutions 2.b.ix Implementation of observational programs in hospitals C. Connecting settings 2.c.i Development of community-based health navigation services 2.c.ii Expand usage of telemedicine in underserved areas to provide access to otherwise scarce services D. Utilizing patient activation to expand access to community-based care for special populations 2.d.i Implementation of patient activation activities to engage, educate, and integrate the uninsured and low/ nonutilizing Medicaid populations into community-based care Domain 3. Clinical improvement projects A. Behavioral health 3.a.i Integration of primary care and behavioral health services 3.a.ii Behavioral health community crisis stabilization services 3.a.iii Implementation of evidence-based medication adherence programs (MAPs) in community-based sites for behavioral health medication compliance 3.a.iv Development of withdrawal management (e.g., ambulatory detoxification, ancillary withdrawal services) capabilities and appropriate enhanced abstinence services within community-based addiction treatment programs 3.a.v Behavioral Interventions Paradigm (BIP) in nursing homes B. Cardiovascular health—implementation of Million Hearts Campaign 3.b.i Evidence-based strategies for disease management in high-risk/affected populations (adult only) 3.b.ii Implementation of evidence-based strategies in the community to address chronic disease—primary and secondary prevention projects (adult only) www.commonwealthfund.org 31 Project number Project name C. Diabetes care 3.c.i Evidence-based strategies for disease management in high-risk/affected populations (adults only) 3.c.ii Implementation of evidence-based strategies to address chronic disease—primary and secondary prevention projects (adults only) D. Asthma 3.d.i Development of evidence-based medication adherence programs (MAPs) in community settings— asthma medication 3.d.ii Expansion of asthma home-based self-management program 3.d.iii Implementation of evidence-based medicine guidelines for asthma management E. HIV/AIDS 3.e.i Comprehensive strategy to decrease HIV/AIDS transmission to reduce avoidable hospitalizations— development of a Center of Excellence for Management of HIV/AIDS F. Perinatal care 3.f.i Increase support programs for maternal and child health (including high risk pregnancies), for example, the Nurse-Family Partnership G. Palliative care 3.g.i Integration of palliative care into the patient-centered medical home model 3.g.ii Integration of palliative care into nursing homes H. Renal care 3.h.i Specialized medical home for chronic renal failure Domain 4. Populationwide projects: New York’s prevention agenda A. Promote mental health and prevent substance abuse 4.a.i Promote mental, emotional, and behavioral (MEB) well-being in communities 4.a.ii Prevent substance abuse and other mental/emotional/behavioral disorders 4.a.iii Strengthen mental health and substance abuse infrastructure across systems B. Prevent chronic diseases 4.b.i Promote tobacco use cessation, especially among low-socioeconomic-status populations and those with poor mental health 4.b.ii Increase access to high-quality chronic disease preventive care and management in both clinical and community settings (note: this project targets chronic diseases that are not included in domain 3, such as cancer) C. Prevent HIV and sexually transmitted diseases 4.c.i Decrease HIV morbidity 4.c.ii Increase early access to, and retention in, HIV care 4.c.iii Decrease STD morbidity 4.c.iv Decrease HIV and STD disparities D. Promote the health of women, infants, and children 4.d.i Reduce premature births Source: New York State Department of Health, Delivery System Reform Incentive Payment Program Project Toolkit, Oct. 2014. 32 Implementing New York’s DSRIP Program: Implications for Medicaid Payment and Delivery System Reform The COMMONWEALTH FUND