Friday Memo- August 9, 2019

Dear Team –

            Community Healthcare Network is a direct service organization. At our core is the delivery of health care to patients and to the communities we serve.

            There are times, though, when serving our patients and our communities, we have to step into the advocacy lane, pushing public policy in the direction that will improve the lives of underserved New Yorkers. Improving lives is CHN’s mission.

            An example of that advocacy kicked in this week. Here is what’s happening:

            CHN stands out among health care providers as a leader in integrating medical and behavioral health care into a coordinated delivery system. In recent years, CHN has built up our behavioral health services to bring better, more comprehensive care to people who come to our health centers for treatment.

            And we have moved beyond our health centers with this care. You all know of our innovation at the East New York Health Hub where we integrate CHN’s primary care with the behavioral health care offered by the Institute for Community Living (ICL). At the Hub, we specialize in serving high need patients, many with a serious mental illness.

            Over the past few weeks we have launched a “reverse integration” initiative centered on our new mobile, the Integration Mobile, to bring primary care to people receiving behavioral care from mental health agencies.

            CHN has been walking the walk to integrate care. But we have also been talking the talk. That is where our advocacy kicks in.

            An antiquated rule of Medicaid billing in New York State says that a health care organization cannot bill for two visits in the same day – even if each visit is necessary for the patient’s well-being. That means if a CHN primary care provider recognizes that her patient would benefit from a visit with a psychiatrist down the hallway, only one of the providers’ visits is billable. 

            Our dentists, podiatrists, and optometrists face the same problem.

            That sounds stupid, right? Especially for a New York State government that, like CHN, talks of the importance of integrating care.  This same day billing prohibition puts an unnecessary obstacle in the way of quality health care integration throughout the state.

            The same day billing rule was not conceived in stupidity, however. A lifetime ago, while in law school, I worked for the City Council’s Health Committee exposing the abusive practice of “Medicaid Mills.” These were private medical practices that would churn patients from doctor to doctor, providing little or no care, but creating multiple bills. Stopping that abuse was important.

            Things change, and community health centers are not Medicaid Mills. Public policy has to evolve, and state regulation has to pivot when necessary for the good of the people.

            This is where CHN’s policy and advocacy kicks in.  Two summers ago, at a conference at the New York Academy of Medicine, a CHN intern stood up before a large audience and asked Jason Helgerson, then head of the state’s Medicaid program, when New York would revise its prohibition on same day billing. Mr. Helgerson said the rule was under study and would soon be changed. This was July 2017. 

            In June 2019, I participated with a number of state officials on a panel discussing integrated health care, highlighting the development by ICL and CHN of the East New York Health Hub. I asked the state officials when the same day rule would be changed. The answer: we are looking at it.

            My blood boiled, the CHN Policy Institute (Kelly Sabatino) got to work, and we wrote to Dr. Howard Zucker, the Commissioner of the state Department of Health, urging action. His staff responded, saying they were looking at it.

            37 states have “looked at it,” and 37 states now allow same day Medicaid billing for more than one visit when more than one health care visit is necessary.

            This week we wrote again to Commissioner Zucker, this time including a sign on letter by 21 other health care organizations joining our demand that the state get into the 21st Century’s commitment to integrating care and ending the harmful same day billing prohibition.  We will keep increasing pressure until we see action. 

            We are not fighting about more revenue for CHN here, although that would be good. It is a battle to help all New York health care providers improve their delivery of care. The best advocacy is always based on the reality of what is really going on in the trenches, in this case our health centers. We know reality.

            CHN will not be distracted from our daily work to care for patients and communities. But when we see a systemic wrong, we will speak out and organize to make a wrong, right.      

            Have a great, sparkling weekend.    -Bob