1. 2015-16 BUDGET AND POLICY PRIORITIES
NEW YORK STATE COALITION FOR CHILDREN’S MENTAL HEALTH SERVICES
PO Box 7124, Albany, NY 12224 • 518.436.8715 • info@cmhny.org • www.cmhny.org • Andrea Smyth, Executive Director • Jackie Negri, Associate Executive Director
The New York State Coalition for Children’s Mental Health
Services represents provider organizations that share the
common work of advancing an advocacy agenda that promotes
the evolution of clinical behavioral health and positive childhood
development. Our 2014 policy paper, “Through the Next Door:
A Discussion of the Child and Family Behavioral Health System
Under Health Care Reform in New York State,” lays out the
Coalition’s support for the concepts and progress associated
with children’s behavioral health redesign. However, it also
raises a concern about how goals such as “population health”
and addressing the social determinants of health can be
narrowed to children who are Medicaid eligible. From our point
of view, the children’s population should be the population of
all children and the “total spend” should contemplate the total
government expenditure during childhood and adolescence
instead of being limited to Medicaid and hospital spending.
If the approach is broadened into a “whole” child spend, than it
requires a commitment from government that reaches beyond
the revenue cycle management focus of Medicaid Managed
Care Organizations. The government “owns” the responsibility
for the population health savings over the long term, because
the taxpayers are the beneficiaries of savings that come
when graduation rates increase among disabled students or
investments in prevention services result in reducing growth in
the number of children referred to specialized Medicaid-funded
behavioral health services.
Based on these beliefs, the transition timetable for managed
care and the growing population of children who will need to
access their behavioral health services through commercial
plans, the Coalition has identified three important priorities for
the children’s behavioral health community for the 2015-16
State Fiscal Year.
1) Child Health Plus – address the inadequate behavioral
health rates offered under CHP to ensure access to adequate
treatment for non-Medicaid youth by funding two years of
government rates for behavioral health clinic visits and begin
to build out the capacity of primary care physicians to support
early recognition screenings by CHP participating primary care
physicians and fund PCP consulting with child psychiatrists
better integrate care.
2) Non Profit Infrastructure Fund – support the $500
millionNonProfitInfrastructureFund,butaddresstheimmediate
capital needs of children’s behavioral healthcare providers by
including a Residential Treatment Facility mortgage buyout
optionandcapitalinvestmentstotransformthisserviceforfuture
service delivery and commercial insurance market demands.
3) A Three Year Planned Investment Proposal
– invest in the services that can slow (prevent) the growth of
populations that need specialized children’s behavioral health
services by earmarking transitional funding for expanding
capacity of services that have been identified as the most
effective or have an evidence-base in improving the lives and
functioning of kids and the capability of family caretakers to
protect and nurture their children.
The Medicaid Redesign Team effort for children’s services,
including the expansion of Health Homes to include children,
continues and is well-regarded. The work is yielding a strong
and prevention-focused benefit package for the Medicaid
program. The Health Home for children’s expansion is also
producing amazing results – by merging in the Early Intervention
care coordination and incorporating trauma impact into eligibility,
the design is getting much closer to true cross-systems,
standardized service design. We appreciated having Coalition
representatives appointed to these efforts and look forward to
finalizing that work. Given the relatively smooth effort on the
Medicaid side, the Coalition would like to turn our attention to
transitional needs and a Prevention Agenda.
NEW YORK STATE COALITION
FOR CHILDREN’S MENTAL HEALTH SERVICES
2. Prevention Agenda
new york state coalition for children’s Mental Health Services
PO Box 7124, Albany, NY 12224 • 518.436.8715 • info@cmhny.org • www.cmhny.org • Andrea Smyth, Executive Director • Jackie Negri, Associate Executive Director
We urge that a serious review of available
community supports for children and families be
undertaken and propose a Three (3) Year Planned
Investment Proposal (TYPIP) to address the lack
of capacity in prevention services. This focus is on
state funded services that “wrap around” kids in the
community is not unrelated to Medicaid Redesign
and we consider the request transitional because
it will support longer term savings by addressing
the social determinants of health (positive youth
development, education success, parenting
capability and avoidable health care costs).
Budget Priorities (Education Budget):
• School Aid enhancements to support
behavioral health interventions – state aid
increases for school districts that train “building-
wide” staff in evidence-based practices, like
Positive Behavioral Intervention Strategies (PBIS)
to improve attendance and achievement statistics
for children with disabilities
• School Aid enhancements to districts that
sponsor school based mental health clinics –
by making behavioral health supports available
to school personnel, emergency removals will
decrease and treatment plan adherence will
improve seat time.
• School aid enhancements for districts that
access community service as an alternative
to out-of-school suspension – funding may
result in contracts with preventive services
providers, youth bureaus and other community
organizations that offer mentoring, youth court
and other community service opportunities to
youth with high truancy and disruptive behaviors
-making their suspensions an opportunity to
access positive youth development assistance.
Budget Priorities (OMH, OASAS, DOH Budget):
• Training and Usage of Teen Intervene –
expand OASAS’ capability to fund and train the
evidence based screening and brief intervention,
”Teen Intervene”, to increase the availability of
an affordable, effective tool to prevent adolescent
substance use and addiction.
• Expand OMH Family Support Services – add
OMH Family Support Services funding so children
and families who are not Medicaid eligible will
not be denied access to a basic peer-to-peer
support and parenting strengthening mechanism
(sustainable as Medicaid increasingly supports
FSS capacity).
• Hold harmless for case OMH management –
currently 40% of children receiving targeted
case management services in the state are not
Medicaid eligible. TCM will be converted to
Health Home for children late in 2015. We urge
a planned transition for current recipients and
funding to address the needs of this vulnerable
population.
• Expand behavioral health integration to
Child Health Plus participating providers
and fund Early Recognition Screening – The
prevalence of non-Medicaid youth using that use
NEW YORK STATE COALITION
FOR CHILDREN’S MENTAL HEALTH SERVICES
(continued on back)
3. Prevention Agenda (cont’d)
Article 31 clinics is negatively affecting the fiscal
stability of those clinics – in addition to providing
transitionalgovernmentratesthroughCHP,funding
to train more primary care physicians (PCPs) in
early recognition screening and then building the
capacity to link the PCPs via telemedicine with
child psychiatrists could help sustain enhanced
behavioral health capacity within CHP networks.
Budget Priorities (OCFS Budget):
• Add funding to programs that support the
Raise the Age initiative and Medicaid Redesign
for exempt children’s services. We have
identified three important expansions that could
give Family Court Judges and Health Home Care
Coordinators more community based options and
also expand primary prevention services. Those
including: Home Visiting – to support positive
parenting skills, adherence to child immunization
schedules, early identification of development
delays; Community Optional Prevention Services
reform – reform this flexible prevention program to
support innovative interactions with JD/PINs and
youth on probation with behavioral health issues
to prevent placement and reduce recidivism; and
Youth Development Program and Runaway and
Homeless Youth Act services to expand positive
youth development opportunities and address the
increasing number of mentally ill homeless and
runaway youth seeking RHYA shelter.
new york state coalition for children’s Mental Health Services
PO Box 7124, Albany, NY 12224 • 518.436.8715 • info@cmhny.org • www.cmhny.org • Andrea Smyth, Executive Director • Jackie Negri, Associate Executive Director
4. Transitional Needs: Non-Medicaid Eligible Youth
new york state coalition for children’s Mental Health Services
PO Box 7124, Albany, NY 12224 • 518.436.8715 • info@cmhny.org • www.cmhny.org • Andrea Smyth, Executive Director • Jackie Negri, Associate Executive Director
As you know, one unintended consequence
related the children’s behavioral health Medicaid
Redesign is the loss of access to appropriate
services by non-Medicaid eligible children. As of
September 2014, there were 6.2 million children
eligible for Medicaid and Child Health Plus in
New York State. In 2013, there were 1.8 million
children eligible for Medicaid-only, so much of the
15.9% increase in the Medicaid/CHP population
between 2013 and 2014 is from the CHP eligible
side. Therefore, to maintain access to specialty
behavioral health services, it is imperative that
the behavioral health benefits offered through
CHP be accessible and strengthened, that CHP
primary care physicians have access to child
psychiatric consultations and be trained in early
recognition screening and that rates be adjusted
to support the additional activities.
Approximately 40% of children and adolescents
receiving OMH targeted case management
services are not Medicaid eligible. This means
that once blended into Health Homes, more
than 2400 children will lose access to care
coordination services because of their insurance
status. Similarly, 40% of children and adolescents
receiving Article 31 outpatient mental health
services are not Medicaid eligible and 25,000
children are at risk of losing access to clinic
services because of their insurance status.
We urge that the state establish transitional
support to maintain access to certain services by
non-Medicaid eligible kids. We believe the plans,
as they become more familiar with the benefits
of early care and the consequences and costs
related to untreated mental health illnesses, will
eventually address rate and benefit inequities.
Until such time we recommend the following:
• Child Health Plus (CHP) rates for behavioral
health visits be funded at the government
rate until the transition of all exempt children’s
populations and services is complete. CHP is the
second most common payer for most Article 31
Child and Adolescent clinics (60% Medicaid; 16%
CHP) This would cost approximately $9 million.
• Expand behavioral health integration to Child
Health Plus participating providers and fund
Early Recognition Screening – The prevalence
of non-Medicaid youth using that use Article 31
clinics is negatively affecting the fiscal stability of
those clinics – in addition to providing transitional
government rates through CHP, funding to train
more primary care physicians (PCPs) in early
recognition screening and then building the
capacity to link the PCPs via telemedicine with
child psychiatrists could help sustain enhanced
behavioral health capacity within CHP networks.
• Maintain the state share of Targeted Case
Management funding that is supporting the
existing caseload of youth who are not Medicaid
eligible until the transition of all exempt children
and services is complete.
neW YorK sTaTe coaliTion
For children’s MenTal healTh serVices
5. Transitional Needs: Physical Plant and Transformation of
Residential Treatment Facilities
new york state coalition for children’s Mental Health Services
PO Box 7124, Albany, NY 12224 • 518.436.8715 • info@cmhny.org • www.cmhny.org • Andrea Smyth, Executive Director • Jackie Negri, Associate Executive Director
The Coalition joins other human services advocates in support of a $500 million Non
Profit Infrastructure Fund. However, we urge that careful consideration be given to the
transformation costs associated with residential treatment facilities (RTFs).
As a sub-class of hospitals, RTFs have been asked to transform their treatment model, reduce
length of stay and, now, due to the federal ACA provisions related to mental health parity,
they must market their services to commercial insurance carriers. Like hospitals, the debt
service on the RTFs is a barrier to transformation. In addition, after five years of rate freezes
the physical condition of most of the RTFs will not attract commercial insurance clients. In
2013, the Coalition commissioned a report by Manatt Health Solutions to identify what was
needed to remove barriers to RTF transformation. A critical recommendation was separating
the operating costs from the capital costs so the debt service does not drive the bed capacity
and instead allows providers to “flex” capacity to actual demand in their communities.
Additional background on RTFs:
• No trend factor since 2011 (when rates were based on 2008 costs)
• System downsizing 540 beds in 2011; 520 in 2014; 514 in 2015
• 100% Medicaid eligible population in 2014; unclear how commercial clients can access
services
Recommendations:
• Initiate a mortgage buy-out program for agencies that sponsor RTFs to de-link the debt
service cost to the need to maintain capacity and support the facilities’ ability to flex capacity
to actual demand
• Set aside funding for capital improvement and renovations to address the neglected
infrastructure, reconfigure 8-bed units into smaller 4-bed units so staffing can flex to capacity
and ensure the facilities are in the physical condition to successfully market services to
commercial payers.
neW yorK sTaTe coaliTion
for children’s menTal healTh serVices