A.5795/S.6072 – QI Funding

This legislation, A.5795/S.6072, would create a new supplemental  quality incentive (QI) program for managed long-term care (MLTC) plans.  While the New York Health Plan Association (HPA) supports funding for a robust  QI program, we oppose this legislation as it seeks to address underlying MLTC payment rate issues in the form of a supplemental quality pool, which would restrict the funding based on a limited set of measures and reallocate funding from other plans, potentially  creating actuarial soundness and rate adequacy concerns.  Further, the legislation fails to create a broader quality incentive program for Medicaid managed care in statute before creating a “supplemental” program.

The QI program has been an essential resource in advancing quality in Medicaid, helping to incentivize efforts aimed at addressing the core causes of health disparities and improving health outcomes for underserved populations.  Further, it has been vital in moving the health care delivery system toward effective, value-based care by enabling health plans to partner with providers on efforts to improve outcomes in primary and pediatric care, integrate medical and behavioral health care, and address social care needs.  We appreciate the Legislature’s efforts to restore funding to the QI program and establish the program in permanent statute in the FY24 budget and believe those efforts should continue to be the primary focus.

This legislation would provide supplemental payments for plans that achieve a four of five-star rating on the latest DOH quality rating guide and have a relative risk score of 1.1 or higher, by allocating $80 million or one percent of  capitation from all other plans to cover the cost of  these quality payments.  We are concerned with focusing on a limited set of measures to award supplemental payments, especially since funding for the broader quality incentive program was eliminated in the FY24 Executive Budget.  Under the existing QI program, plans currently are measured on outcomes intended to improve the quality of care and only receive incentive funding for achieving superior results.  The QI funds plans receive are used to support partnerships with providers and community organizations, such as providing in-home wellness visits for home-bound individuals, covering the cost of healthy food home delivery programs to members with chronic conditions, and investments in test innovative care models.  Limiting funding only to those plans that achieve a four of five-star rating and have a risk score of 1.1 or higher will jeopardize the ability of health plans to support these partnership programs that benefit the communities they serve.  Further, reallocating a portion of the capitation rate could create actuarial soundness and rate adequacy concerns as A.5795/S.6072 would reduce the overall funding for the entire MLTC program.

While funding for the Medicaid QI program has been consistently reduced over the past several years and we appreciate the focus on making funding available to support quality improvement efforts, the QI program should be adequately and consistently funded and not result in a reduction of overall funding for the MLTC program.

For all these reasons, HPA opposes A.5795/S.6072.