Social Care Networks – NY

The initial RFA for New York was posted weeks ago and got rather thorough coverage so I didn’t need to discuss it here – though (predictably) I have many thoughts on the matter.

Hot off the press today is an addendum. It’s a pdf but I’ve chopped it off so the link over there 👈 is just the 1st two pages of the addended document – all of which is here ICYMI.  I’ll review the addendum (changes in red) below with some commentary:

AddendumMy Comments

Note that this constrains the participants. Removing “including” means that others need not apply – clearly this precludes hospitals, health plans, or BHCCs from applying unless they were PPSs before.

I think this one just fixes a typo / forgotten word.

I’ll take this opportunity to get on my soap box to reiterate the reality that this requirement is a big deal, and a very good policy decision that DOH made in the crafting of this RFA.

More than 1/2 of the governance needs to be from CBOs. 

This would disqualify the vast majority of the DSRIP PPSs from the previous waiver, unless they play some sort of jujitsu by creating new daughter entities in (very) short order and have those entities do the application.  The policy goal here is clear: take the control away from the incumbent (medical) enterprises that still generate the majority of their revenue from fee-for-service care and therefore have conflict of interest with the policy goals of the program – which is to invest upstream – thereby reducing the quantity of fee-for-service care – especially acute care.  We saw (and felt) this all-too-often in DSRIP.  It’s great to see that DOH is taking this seriously.

DOH will be on the lookout for the jujitsu governance shenanigans and will disqualify applications that lack transparency of true CBO controlled governance.

Relaxing this requirement a bit – which I agree is appropriate.  Federal EINs are easy to come by – and this adds agility to the SCN.  Agility is necessary.  SCNs will need to be able to add and delete entities quickly so they can respond to the dynamic needs of their communities, and to hold their collaborating entities accountable.  Without this agility, SCNs will fail to accomplish their objectives (as did many PPS).
a) Removing 3 meals a day without constraints.  This may have been seen as a loophole too-big-to-retain, and may not have sufficient evidence to support trie ROI for the program with reduction in total cost of care.

b) Specifying that MTM is expected and that there needs to be a clinical justification for such comprehensive food assistance.

c) $1M as an upper threshold for CBOs would eliminate several of the effective CBOs such as Jewish Board in NYC and Catholic Charities upstate.