In an amendment request to its 1115 Medicaid waiver, New York State is proposing a $325 million investment in nine Health Equity Regional Organizations (HEROs) that would serve as coordinating entities for formalized partnerships between managed care organizations, hospitals, community-based providers, and other stakeholders.
The HERO program is part of a larger $13.5 billion request to continue transformation of the state's Medicaid program.
Similar to the Accountable Health Communities model in states such as Hawaii, or Washington’s Accountable Communities of Health bodies, HEROs would focus on collaboration and coordination, and facilitation of activities that best address the needs of the communities they serve (with the goal of raising the overall health of these communities).
The New York Department of Health (DOH) said HEROs will be structured to replicate the successes of the Delivery System Reform Incentive Payment (DSRIP) program, while also incorporating changes informed by the challenges encountered and lessons learned throughout the program. The DSRIP program included the creation of 25 Performing Provider Systems, which were local collaboratives of safety net provider partnerships that were awarded the ability to earn performance incentive payments to move the needle on reducing avoidable admissions and achieving clinical outcomes, which included moving PPS partners toward pay-for-performance arrangements. The PPSs were regional entities across the state, and some had overlapping geographic coverage areas.
To ensure a comprehensive and coordinated regional approach, New York seeks to authorize only a single HERO per region based on the nine historical regional divisions utilized by DOH for Medicaid Managed Care Organization rate setting, CMS Health Insurance Market Reforms, and to measure public health outcomes. However, DOH would consult with local health departments and other key stakeholders to sub-divide these regions based on compelling evidence that such further divisions would enhance the work of HEROs. To that end, the HERO would serve as a collaborative body bringing together key stakeholders, serving as the central point of regional planning and coordination around health equity improvement initiatives, and leveraging any existing public health planning activities that are ongoing within regions, including those initiatives spearheaded by local health departments.
Letter from SHIN-NY participants
In a May 2022 letter to the DOH, the six regional health information organizations that make up the Statewide Health Information Network for New York (the SHIN-NY), and the New York eHealth Collaborative (NYeC) noted that the waiver plan envisions HEROs would be charged with carrying out a vast array of activities and collaborative efforts – one of the most complex and expensive of which is building the technology infrastructure needed to accomplish the aims of the waiver. “However, more than a decade ago, New York State had the foresight to envision and support the SHIN-NY, a statewide health information exchange, and we urge the state to leverage this resource now. We recommend strong consideration for establishing QEs [qualified entities] 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 authors of the letter also noted that there operational issues are emerging in states such as California and North Carolina that have begun to implement their waiver plans. New York must be prepared for the key operational questions and issues that will arise and need to be addressed both prior to and during the waiver’s implementation, they said. “We propose that 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. Based on the SHIN-NY’s experience in standing up and implementing a network of technology platforms for health information across the state, we are uniquely positioned to assist the state in identifying and solutioning issues and navigating challenges in an implementation of such magnitude.”
The letter notes that interoperability and data standardization will be key to the work of the HEROs in analyzing data, identifying equity priorities, building consensus around interventions, and applying lessons learned. “The SHIN-NY has deep experience in data management and data governance, and has been focusing on data quality initiatives over the last year. As noted above, at a minimum, a formal relationship between the HEROs and the SHIN-NY can help the state to leverage our existing experience and expertise in data standardization to support and strengthen the work of the HEROs.”
