Position Papers
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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