Policy & Advocacy

Position Papers

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.

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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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