Advocacy Agenda

2017 Priorities

  • Memos of Support/Opposition
  • Focus on the quality of New York's delivery system reforms, not the quantity. Thorough implementation and legislative oversight of Medicaid waiver programs should be completed before undertaking new initiatives that will disrupt the private insurance market.
  • No return to regulated insurance rates. Suburban hospitals already are disadvantaged in commercial insurance reimbursements.
  • Level the playing field among providers through regulatory relief.
  • Invest in the healthcare workforce of the future. Don't mandate a staffing model from the past.
  • Suburban hospitals have earned their fair share of the state's savings after contributing their fair share to ease New York' budget crises.

Position Summaries:

Regional Planning

The Suburban Hospital Alliance appreciates the positive role that collaborations among providers can play in addressing local and regional health needs, and generally supports efforts to bolster the kinds of interdisciplinary partnerships that are occurring naturally in our communities as a result of health care reforms. We are concerned that the establishment of formal organizations to oversee regional planning, could have the opposite effect by establishing a statewide template for health care planning that does not reflect the variations in community needs and provider configurations. At minimum, any regional collaboratives should not have a role in approving or making recommendations on Certificates of Need (CON). The Department of Health could more constructively facilitate collaborative efforts around population health by developing data on health care trends and patient populations, and by offering these tools to providers and community organizations. Accelerating the implementation of the state's all-payer database would provide another critical resource for parties working to implement the state's Prevention Agenda initiatives.

Health Benefit Exchange (Marketplace)

Hospitals in the suburban regions fully support expansion of coverage to the uninsured but remain concerned about the impact that the state Exchange plans will have on reimbursement rates, uncompensated care, and bad debt. We are particularly concerned about the migration of patients to high deductible or limited benefit insurance plans under the Exchange, which will decrease the number of patients who are technically insured but lack the ability to pay deductibles or non-covered expenses. It is highly unlikely that hospitals will be able to collect the high deductibles and co-payments required by the Exchange plans, particularly the catastrophic, bronze, and silver-tier plans. Coupled with the lack of out-of-network benefits in any of the Exchange plans, downward pressure on reimbursement rates and the failure to ensure that every plan offers robust provider networks, these plans will shift a significant financial burden onto hospitals. The state should require that gold and platinum-tier plans offer out-of-network options, scrutinize the actual provider networks contracted by each plan, and develop a mechanism for compensating hospitals who incur substantial bad debts from unpaid Exchange deductibles.

Regulatory Fairness

The Suburban Hospital Alliance appreciates the efforts made to date by the Legislature and Department of Health to address some of the state's burdensome health care regulations, but encourages further progress. Specifically, we strongly encourage efforts to level the playing field between hospitals and competing types of providers offering the same services in alternative settings. This leveling is best accomplished by reducing the number of administrative approvals and costly, burdensome CON applications that are required of hospitals but not of physician practices for the same or similar services. Reducing barriers to changes in service mix will allow hospitals to be more efficient, more responsive to community health needs, and better able to form the kinds of integrated care networks that are critical to the transformation of the delivery system. Hospitals also need relief from regulatory restrictions that hinder access to capital and unfairly advantage freestanding ambulatory centers and other competing providers who are not obligated to treat uninsured and publicly insured patients.

Shared Savings for Providers

In 2011, the hospital community agreed to a 2 percent rate cut and a series of policy changes intended to keep the growth in Medicaid costs below the rate of medical inflation. That commitment has been fulfilled by providers, despite a sharp increase in the number of Medicaid enrollees over the same period. The rate cut expired at the end of the 2013-2014 fiscal year, as proposed in the Executive Budget. Having shared the sacrifice necessitated by the state's fiscal crisis, hospitals now should be afforded the opportunity to share in the savings garnered from the Medicaid Global Cap. The needs of suburban hospitals serving a disproportionate share of low-income and complex patients also must be addressed. Reinvestment in the hospital sector will allow us to make the investments in infrastructure, technology, and workforce necessary to transform the delivery system.

Workforce

The Suburban Hospital Alliance opposes efforts to legislate hospital staffing ratios, which would force a "one size fits all" approach on hospitals and health systems who must on an hourly basis adjust their staffing levels to reflect patient acuity, experience and skill levels of individual caregivers, and patient needs. In today's dynamic health care environment, organizations must have the flexibility to design multi-disciplinary teams of clinical professionals to ensure the highest quality care. A rigid and extremely expensive staffing mandate fails to take into account the fiscal and operational realities of hospitals in these regions, and will only jeopardize patients' access to care. The Legislature could more effectively contribute to improved patient care through initiatives such as proposed "BSN in 10" legislation, which would require all associate's degree nurses to earn their bachelor's degrees in nursing within 10 years of beginning practice, and by encouraging the expansion of nurses' scope of practice, so that they may practice to fullest extent of their education and training.

Meaningful Tort Reform

Hospitals in the suburban regions pay some of the highest medical malpractice premiums in the country, and costs continue to rise. This increases the cost of care for consumers, employers and the state, while physicians leave New York to practice elsewhere. New York is in need of true malpractice reform that balances the rights of patients to receive fair compensation and the need for rational procedures and limitations that keep malpractice premiums affordable. The Suburban Hospital Alliance will continue to oppose legislation that will further tilt the balance in favor of plaintiffs and their counsel and increase premiums.

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