Policy & Advocacy

Position Papers


Coalition Comments on Integrated Outpatient Services - Part 404
December 3, 2014

Integrated Outpatient Services

Coalition Comments on DRAFT Health Home Application to Serve Children
July 29, 2014

Letter to Governor Cuomo
July 8, 2014
The Coalition congratulates and thanks the Governor for his leadership resulting in the enactment of comprehensive legislation to combat the opiod epidemic of heroin and prescription drug misue and addiction in New York State.

Letter to Governor Cuomo

Residential Redesign - Information Required for Consideration of Proposed OASAS Residential Model, Submitted to OASAS
June 18, 2014
The Coalition submitted a set of questions prepared by affected Coalition providers regarding the proposed OASAS residential redesign.

Information Required for Consideration of Proposed OASAS Residential Model

Memorandum of Support - Bill No. S.7882/A.9943-B
June 17, 2014
An Act to amend the insurance law and the public health law, in relation to requiring health insurance coverage for substance abuse disorder treatment services and creating a workgroup to study and make recommendations.

Memorandum of Support - Bill No. S.7882/A.9943-B

Coalition Comments to the Office of Health Insurance Programs, DOH On Admission of Children to Health Homes
March 17, 2014
In previous comments The Coalition strenuously argued that diagnosis alone should not be the eligibility criteria for children. However CMS requires eligibility for health homes to be condition based, not population-based, so these comments include Coalition suggestions for eligibility.

Coalition Comments to the Office of Health Insurance Programs, DOH On Admission of Children to Health Homes

Coalition 2014 Albany Advocacy - Legislative Talking Points
March 11, 2014
Coalition staff and members spent the day visiting state legislators and voicing support for budget items related to preparation for the managed care carve-i; expanding community-based services; shoring up linkages and support for health homes; enhancing and developing supportive housing; funding to address NY's prescription drug and heroin epidemic and the MRT waiver implementation. The group also pressed for increasing base clinic rates and addition funding for OMH rental stipends.

Coalition Comments on Children's Health Homes to the Children's Health Home Workgroup
February 27, 2014
The Coalition is committed to ensuring that health homes have the expertise and experience working with children and families and are able to meet all of their needs. The Coalition solicited feedback from our members on the three elements of a health home model. The three elements are: Health Home Network Requirements, Approach to Delivery of Six Core Care Management Requirements, Health Home Eligibility Criteria/Requirements. Our comments on these points are in the 5 page paper along with additional comments.

Coalition Comments to the State’s Children’s Health Home Workgroup

Coalition Comments on the State Healthcare Innovation Plan (SHIP)
December 2013
After carefully reviewing the plan, The Coalition emphasizes the importance of behavioral health in meeting SHIP’s goals.  The role of community-based behavioral health organizations is highlighted, and how CBOs must be part of the plan’s solutions, whether it involves integration, workforce development or health information technology (HIT) support.

Coalition Comments on the State Healthcare Innovation Plan (SHIP)

Behavioral Health for New York City's Future, 2014
November 2013
This Coalition NYC briefing paper is written to advise our policymakers and highlight behavioral health issue in New York City as we transition to a new Administration and City Council in 2014.  Community-based nonprofit mental health and substance use service are at the crux of a number of policy issues facing the City next year: health care, homelessness, criminal justice service, etc.  We hope this paper will provide guidance for the development of improved policies and programs.

Behavioral Health Moves to Managed Care: The Coalition’s View
June 2013
A product of The Coalition’s ad hoc “think tank” and its Board of Directors, Behavioral Health Moves to Managed Care: The Coalition’s View represents our latest thinking on the complex issues that underlie the significant and speedy transformation of our sector to integrated and managed care.

Coalition Supports MRT 1115 Waiver Amendment (aka Super Waiver)
August 15, 2012
Overall, the waiver would make available $10 billion in federal Medicaid savings to be reinvested in the state's health and behavioral healthcare system over a period of 5 years.

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Coalition Submits Comments on Proposed Regulations by OASAS and OMH on Limits on Adminstration Expenses and Executive Compensation
July 16, 2012
Coalition comments on the Limits on Administrative Expenses and Executive Compensation ASA-22-12-00014-P and OMH-22-12-00019-Pregulations that were proposed by the Office of Alcoholism and Substance Abuse Services and the Office of Mental Health to implement the provisions of Executive Order No. 38, which seeks to limit executive compensation and to reduce administrative expenses within entities that contract with the State of New York.

Coalition responds to NY State Department of Health Proposal for Demonstration to Integrate Care for Dual Eligible Individuals
April 20, 2012

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Coalition strongly urges Governor Paterson to not appeal Adult Homes Decision
October 1, 2009
The Coalition urges Governor not to appeal the Federal District Court decision by Judge Nicolas G. Garaufis, which find New York State in violation of the Americans with Disabilities Act by failing to house over 4,300 people with mental illness in the most integrated settings appropriate to their needs.

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Coalition comments on the preliminary definition of “Meaningful Use”, as presented to the HIT Policy Committee on June 16, 2009
June  26, 2009
The Office of the National Coordinator for Health Information Technology (ONC) should reevaluate the incentives used under Medicare and Medicaid to ensure that there is equity among provider types. Medicare and Medicaid incentives currently do not include behavioral health and addiction providers. The Coalition strongly urges Congress and ONC to include community-based mental health and addiction providers in all federal HIT initiatives to ensure that individuals with mental illnesses and addiction disorders have access to the overall health benefits of provider usage of HIT.

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Coalition Supports Rescinding CMS rules which covered School-Based Services, Outpatient Services Definition and Partial Rescission of Case Management Services.
May 28, 2009
The Coalition strongly supports CMS-2287-P2, which rescinds harmful Medicaid regulations that would have negatively affected many providers, and by extension have a detrimental impact on Medicaid beneficiaries, particularly children in foster care, individuals with physical or mental disabilities and substance abuse disorders or other chronic health conditions.

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The Coalition strongly supports the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008
May 28, 2009
Coalition makes specific recommendations as they pertain to the comments solicited.

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Coalition Opposes Assembly Bill A.7647
May 18, 2009
This bill, if enacted, would require new minimum training requirements of boards of directors for certain voluntary not-for-profit agencies that contract with the Office of Mental Health (OMH) and Office of Alcoholism and Substance Abuse Services (OASAS).  The Coalition believes this unjustly singles out non-for-profits that contract with the OMH and OASAS among human services providers.

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Coalition Supports Assembly Bill A.844 (Gottfied) / Senate Bill S.3835 (Duane)
April 20, 2009
This bill, if enacted, would end the second class treatment of dual eligibles at the pharmacy counter, restoring them to a cost protection now provided only to Medicaid beneficiaries who lack Medicare.  A884/S3835 would protect dual eligibles, like all other Medicaid recipients with a $200 annual ceiling on all co-payments, resulting in fewer elderly and disabled New Yorkers leaving the pharmacy without their medicine.

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Coalition Signs on to AMA Health Insurance Code of Conduct
April 17, 2009
The AMA House of Delegates passed a resolution in November of 2008 to draft and adopt a National Health Insurer Code of Conduct. According to the resolution, the AMA code will set forth clear and concise principles addressing both medical policies and payment issues, as well as create a mechanism to monitor compliance by managed care companies.

View » Petition for Health Insurer Code of Conduct Garners Widespread National Support

Memorandum in Opposition to Assembly Bill A.5386
March 31, 2009
The Coalition of Behavioral Health Agencies opposes this bill as it fails to make Timothy’s Law,
New York State’s landmark mental health parity law, permanent.

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Letter to OASAS Commissioner Karen M. Carpenter-Palumbo regarding the draft revision of Part 822 of the Mental Hygiene Regulations.
March 19, 2009
In reading the regulations we are concerned about the ambiguity of language in various sections as it references “services” “visits” “sessions” and “days”....We believe that the assessment, evaluation, initial treatment and continuing treatment planning procedures and the Quality Assurance and Utilization Review processes be re-aligned so that OMH and OASAS outpatient clinics will be governed by the same rules.....Coalition members frequently voice concern about the difficulty in hiring certain professional groups such as psychiatrists, physicians and nurses.

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Letter to Governor Paterson regarding proposed cuts to Supplemental Security Income

January 12, 2009
"The Coalition of Behavioral Health Agencies strongly opposes the proposed cut to the Supplemental Security Income (SSI) state supplement contained in the Governor's Executive Budget for 2009-2010 and urges you to restore this cut."

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Comments on CMS Proposed Regulations for Medicaid Program: Home and Community-Based State Plan Services [1915(i)]

June 3, 2008
While we applaud CMS for introducing a whole new concept and option for providing Medicaid services to vulnerable populations, we are deeply concerned that the proposed regulations will pose additional barriers and prove to be more burdensome for providers, including non-profit community based organizations. The Coalition believes the proposed regulations should maximize flexibility and the use of community-based services.

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Comments on CMS interim final rule for Medicaid Optional State Plan: Case Management Services.

January 29, 2008
Case management services are a critical Medicaid benefit that helps millions of low-income
children and adults with disabilities gain access to needed medical, social, educational and other
services. The interim final rule makes changes that go well beyond the policies established by
Congress in the Deficit Reduction Act of 2005 (DRA, PL 109-171). Implementation of the rule
would have a detrimental impact on Medicaid beneficiaries, particularly children in foster care
and individuals with physical or mental disabilities or other chronic health conditions.

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Comments on CMS Proposed Regulations for Medicaid Program; Clarification of Outpatient Clinic and Hospital Facility Services Definition and Upper Payment Limit

October 29, 2007
These regulations are likely to negatively affect many providers, and by extension many consumers of service, and should not be allowed to take effect without major scrutiny and widespread opportunity for analysis, stakeholder comment and possible modification.

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Comments on CMS Proposed Regulations for Coverage for Rehabilitative Services under the Medicaid program

October 2, 2007
We are deeply concerned that the proposed regulations will pose additional barriers and prove to be more burdensome for providers of rehabilitative services, including non-profit community based organizations. We fear the new regulations will result in a decrease in both the quality and quantity of services individuals receive.

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Reform and Restructuring of Article 31 Clinic Reimbursement Methodology

July 16, 2007
This paper proposes replacing the current static reimbursement methodology with a uniform system-wide rate that reflects direct and indirect costs of delivering clinic services and that will ensure successful outcomes for consumers.

The Coalition received the 2008 Grassroots Advocacy Award from the National Council of Behavioral Healthcare at its 38th annual conference in Boston on May 2, 2008, for its work on Article 31 clinic rate methodology reform.

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The Coalition's Statement of Concerns and Issues Concerning the Conversion and Implementation of the Assertive Community Treatment Program

October 3, 2003
Highlights of concerns, issues, and challenges of implementing the ACT program under a Medicaid reimbursable model.

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Salary and Turnover Survey of Community Based Mental Health Agencies in New York State for FY2000

A survey of salaries and turnover in community-based mental health agencies in New York State shows high turnover and poor retention among direct-care staff. The survey further compares salaries and turnover in agencies that employ union workers and those that employ non-union workers, as union workers are typically able to negotiate wage increases or Cost of Living Adjustments (COLAs) with some regularity. The survey demonstrates that union agencies pay higher salaries while having lower turnover and greater retention of experienced staff than their non-union counterparts. Lower turnover translates into better care, as service recipients experience fewer disruptions in the continuity of care.

Survey »
Appendix A: Turnover and Salary Questionaire »

PROS: Latest Information

Information on PROS (Personalized Recovery Oriented Services) and The Coalition's position.

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