October 4, 2018: Albany, NY:
DRNY submitted comments on the Department of Health (“DOH”) and the Office for People with Developmental Disabilities (“OPWDD”) proposal:
New York State Medicaid Managed Care Organization I/DD System Transformation Requirements and Standards to Serve Individuals with Intellectual and/or Developmental Disabilities in Specialized I/DD Plans – Provider Led (SIPs-PL) (“Plan”)
We appreciate DOH and OPWDD’s commitment to these goals. However, the current plan for a successful transition to managed care is grossly deficient.
While the Plan is couched in language of improving access to services, it appears quite unlikely MCOs will actually be able to do this given the significant discretion entrusted to the agencies, conflicts of interest, and existing systemic barriers in the OPWDD service delivery system. In addition, under a capitated payment model, MCOs would have an incentive for people to underutilize services. Ultimately, this will result in lack of access to community based services and increased institutionalization of individuals with complex needs.
As written, DOH and OPWDD should not implement this Plan, as it will have profound negative effects on individuals with intellectual and developmental disabilities. OPWDD and DOH must conduct further outreach to stakeholders, and provide clarification, measurable outcomes, and further development of its proposal to ensure access to necessary services for people with intellectual and developmental disabilities.
DRNY, as the federally mandated Protection and Advocacy System, has repeatedly offered to work with the State to ensure this process works for New Yorkers with disabilities.
DRNY’s comments may be found here:
DRNY is the designated independent non-profit Protection & Advocacy System empowered by Congress to investigate allegations of abuse and neglect and provide legal and non-legal advocacy services to people with disabilities in New York State. The Protection & Advocacy System was created by Congress as a direct result of the horrific conditions that were uncovered in the 1970's at New York’s Willowbrook State School.