The SHIN-NY and NYeC Submit Comments to DOH on the NYS Proposed 1115 Waiver Amendment Request

On May 20, the entities that make up the SHIN-NY – NYeC, HealtheLink, Rochester RHIO, HealtheConnections, Hixny, Healthix and Bronx RHIO – provided comments in response to the New York State’s proposed 1115 waiver amendment request, “Strategic Health Equity Reform Payment Arrangements: Making Targeted, Evidence-Based Investments to Address the Health Disparities Exacerbated by the COVID-19 Pandemic”.

In these comments, the SHIN-NY entities recommend:

  • Strong consideration for establishing QEs as the HEROs or a formal relationship between the HEROs and the SHIN-NY, which would allow the HEROs to take advantage of the State’s investments in the SHIN-NY technology infrastructure while ensuring that waiver funds are focused and directed where they can have the greatest impact – supporting the needs of the HEROs’ communities.
  • The State, in partnership with the SHIN-NY, engage in a multi-stakeholder planning process at the earliest possible opportunity to begin to identify and address issues such as policy and governance.

Read the full SHIN-NY comment letter here.

NYeC also submitted comments in which we recommend:

  • New York State should press for data collection and aggregation to be in a uniform statewide format and be centralized within a single statewide system.
  • To effectively develop a develop a “statewide IT social needs referral and data platform infrastructure”, the new social needs referral and data platform must be tightly integrated with the existing SHIN-NY network of clinical data.
  • Social factor data can be as sensitive as clinical records, and the data use policies for these data should be carefully developed, monitored, and maintained.  Unifying data use policies between clinical and social factor data would be an efficient way to address the need.
  • The SHIN-NY entities work collaboratively on a unified plan to support the waiver implementation across the nine regions, recognizing that their engagement can be extremely valuable if well-coordinated.

Read the full NYeC comment letter here.