On October 12 the Coalition of Medication-Assisted Treatment Providers and Advocates (COMPA), a New York coalition of opioid treatment programs (OTPs) and medication assisted treatment (MAT) providers, released its budget and policy agenda for 2024. Among the priorities: investing in the workforce, preventing OTP closures due to OMIG audits, supporting overdose prevention sites, and increasing the focus on integrated treatment. Below is the full message.
According to the Centers for Disease Control and Prevention, more than 107,000 people died of drug overdoses in the United States during the 12-month period ending April 2021. Data from the New York Comptroller’s report (11/22/22) shows that opioid overdose deaths increased in New York between 2019 and 2021 by about 68%. The report states that 30 New Yorkers per 100,000 died from drug overdoses in 2022, compared to 25 per 100,000 in 2021 and 5 per 100,000 in 2010. The opioid overdose death rates in New York State exceeded national rates in both 2020 and 2021. Furthermore, there was a 78 percent increase in overdose deaths in NYC since 2019 and 27 percent since 2020.
The isolation and despair of the COVID-19 pandemic contributed to this tragic reality along with the increase of opioid-related illicit fentanyl and similar synthetic opioids. It is crucial to recognize that overdose deaths for all racial and ethnic groups grew; however, the rates increased nearly five-fold for Black New Yorkers, quadrupled for Hispanic or Latino New Yorkers, and tripled for White New Yorkers.
Opioid Treatment Programs (OTPs) and Medication-Assisted Treatment (MAT) providers are on the frontlines of fighting the overdose epidemic. There are 110 OTPs in New York serving over 44,000 New Yorkers. These essential providers assist those struggling with opioid dependence through MAT, which combines individually tailored behavioral therapy with clinically effective medications. Currently, only 32 counties out of 62 in New York State have an OTP. If we want to ensure that all residents can access care, we must increase investment in these programs.
As New York continues to struggle with the increase in deadly overdoses across the state, it is vital that the State support policies and provide funding that increase access to MAT and remove barriers which impede that access. COMPA recommends that New York focus its response on the areas outlined below.
Invest $500 million in the workforce and include a 3.2% COLA tied to Consumer Price Index:
OTPs and MAT providers are unable to treat patients up to their normal capacity due to a staffing shortage. Program staff is underpaid, overworked and burnout is high. The workforce shortage must be addressed so that access to MAT can be maintained and expanded.
- 3.2% COLA increase: Providers have been denied nearly $500 million in COLA funding despite a New York statute that mandated providers be paid a COLA tied to the CPI, the state has deferred it multiple times. New York should make the COLA permanent and provide a 3.2% COLA this year to help sustain the workforce.
- Invest $500 million in the workforce: In order to address the workforce crisis in a meaningful way, New York should invest $500 million to help offset the lost COLA funding. Programs to provide loan forgiveness, internship stipends and stipends for CASAC trainees, and fellowships in addiction medicine would help build and maintain the workforce, particularly in underserved areas.
Prevent OTP closures due to OMIG audits:
In 2022, Governor Hochul vetoed S.4486-A (Harckham)/A.7889 (Gottfried) (2022), which would reform the Medicaid audit process of the Office of the Medicaid Inspector General. The current process is focused on meeting a pre-determined fiscal target at the expense of providers who have not engaged in fraud or abuse. This aggressive approach threatens to destabilize the OTP system and has already resulted in the loss of one program that served 1,500 patients.
The COMPA supports passage of S5329-A (Harckham)/A6813 (Paulin), which would enact the reforms contained in the vetoed bill. In her veto message, the Governor acknowledged that the audit processes should not place an undue burden on providers and directed OMIG to take steps to address the concerns that underlie the bill. COMPA believes that the appropriate approach is outlined in the legislation and supports its passage.
Establish and enhance integrated services: COMPA opposes the merging of OASAS and OMH, but it strongly supports the integration of care. Integration can be addressed in the state budget or through legislation.
- Establish comprehensive outpatient services: COMPA supports S.2704 (Harckham) A.3807 (Jackson), which authorizes DOH, OASAS, and OMH to jointly establish a single set of licensing standards and requirements for comprehensive outpatient services centers. The focus of this bill is to ensure that people can seamlessly access services for co-occurring mental health and substance use disorders while also accessing necessary primary care services.
- To encourage and facilitate integration, COMPA recommends an overall investment in SUD outpatient treatment to include:
- Establishment of an add-on rate for services provided by higher credentialed, licensed staff.
- Increased reimbursement for medication management.
- Increased reimbursement rate for OTP services to match SUD outpatient rate. This should include excluding the cost of toxicology for OTPs from the rate as it is for SUD programs. Medicaid should directly cover this cost.
Enforce network adequacy to increase access to treatment in commercial networks:
The final FY 2023-24 state budget included requirements on network adequacy. The law directs DFS and DOH to promulgate regulations in consultation with OMH and OASAS to ensure that providers are included on insurers’ panels. Unlike the Governor’s original budget language, the final language is vague and does not direct the plans to include specific criteria. Implementation of this law must ensure that ALL OTPs and MAT prescribers can participate in managed care networks of all commercial insurance plans.
Too often people with commercial insurance seek OTP treatment and discover that although the service is covered, the insurer does not have any OTP providers in its network. In addition, the final budget language did not include any proposals on enforcement. It is essential that the State enforce the new law. COMPA would support policy proposals that address enforcement.
Require Medicaid managed care companies (MMCC) to pay the correct rate: The Medicaid managed care model contract that facilitated the transition to managed care in 2015 allows MMCCs to utilize two different types of software to process claims: the APG grouper or a company’s similar proprietary version. Claims processed through the MMCC’s own software are often inaccurate and result in underpayments to the providers, while the APG grouper software results in accurate payments. This is particularly a problem when a change is made to the current billing system, like the addition of a new service or code. Providers should receive full payment for services rendered. COMPA supports the introduction of legislation to require the utilization of the APG grouper software to rectify this problem.
Establish a taskforce to address the siting of SUD clinics: COMPA is grateful for the State’s role in directing the over $2 billion in opioid settlement dollars to initiatives that expand prevention, treatment, recovery, and harm reduction. As access to services increases, it is critical that communities are engaged in a more structured manner. COMPA supports the creation of a taskforce to assist communities and providers in determining where programs and facilities should be sited. Given the severity of the epidemic, it is crucial that more programs are opened, particularly in underserved areas. A taskforce can help communities navigate the siting process and ensure that programs are strategically placed throughout the state.
Establish overdose prevention sites: COMPA supports this policy as an important part of harm reduction efforts if it is accompanied by protocols to establish connections to treatment. Evidence demonstrates that these programs prevent overdose deaths and play a critical role in combatting the opioid epidemic. COMPA urges passage of S.399-A(Rivera)/A.338-A (Rosenthal).
For additional information, please reach out to Allegra Schorr at email@example.com.