Jan 27, 2021
Thank you for the invitation to provide comments today regarding the three-year extension of the Section 1115 Medicaid Redesign Team (“MRT”) waiver.
My name is Andrea DeMeo, and I am the President and CEO of Trillium Health.
Trillium Health is dually designated as a Federally Qualified Health Center (FQHC) Look-Alike and a Ryan White HIV clinic, located in the heart of downtown Rochester, NY, and we have served our community for more than 30 years.
While we are generally supportive of the intention of the waiver, and the goals of DSRIP, we are extremely concerned about the pharmacy carve out and do not agree with this recommendation.
This move will be financially devastating to safety net providers like Trillium Health, and cause significant disruption in services and further confusion for patients all in the midst of navigating and responding to COVID-19. The Governor himself just recently highlighted that 1.6 million New Yorkers are now insured under Medicaid-- it is these very people who will be hurt by the carve out of the pharmacy benefit which will eliminate the discounts from the safety net providers resulting in cutting services to those who need it most.
As a Ryan White clinic participating in the 340B drug discount program, we provide services to low income individuals living with HIV. This benefit allows us to provide wrap around services that engage and retain people into care, support medication adherence and ultimately reduce viral load and thereby, transmission of infection. These expanded services are critical to patients living with HIV/AIDS as well as the goal of the Ending the Epidemic in NYS.
As a Federally Qualified Community Health Center, we also receive discounts on prescriptions that allows us to provide these same expanded services to people and families with low-income or living in poverty. With this carve out, access to prescriptions, as well as other critical healthcare and supportive services we provide our community, will be at significant risk.
In the Governor’s budget proposal, he highlighted the importance of investing in food and housing security programs—which would be almost impossible for us to continue without the 340B program.
Although the Governor has allocated some funding in his budget for safety net providers, in lieu of keeping the benefit intact, it is simply nowhere near enough to cover the deficit and the impact on services as a result of this carve out.
There will never be a time when this proposal makes sense—but especially now, as COVID-19 continues to ravage our communities and disproportionately affect communities of color. This proposal is plainly nonsensical and dangerous for the safety of every New Yorker.
We have been called upon to provide COVID testing and vaccinations for priority populations—all with no additional staffing or resources, while simultaneously trying to maintain all of our existing programs, clinics, and services.
To address testing and vaccine equity, we have established testing and vaccine sites, worked with community centers, public housing sites and nursing homes, participated in helping to educate on the safety and efficacy of the vaccine, and stand ready to redeploy our mobile clinic to further address the inequities existing in communities of color. We have administered every single vaccine in accordance with the guidelines with no waste and have had vaccine redistributed to us because of our effectiveness in getting vaccines into arms, and are now called upon to help with community pop up vaccination sites.
Our patients and our communities trust us. Without the 340B drug discount program we will not have the resources we need to be able to continue down this path doing the work we are called upon to do.
And then there is the opioid epidemic. We operate a harm reduction program to address the opioid epidemic that continues to ravage our community.
Anecdotally, we are finding that people have fallen back into drug use during the pandemic. We are also seeing an increase in HIV clusters in our county.
And it should come as no shock that we are witnessing this trend. We need the resources to continue to be a trusted provider who stands ready to address these complex, intermingled health trends.
On behalf of our patients who are some of the most vulnerable New Yorkers. We propose that the governor approves bills A.1617 in the Assembly and S.2520 in the Senate, which will allow us to pause for 3 years to allow time for a meaningful solution, so we may continue to provide the highest quality of care to the most vulnerable members of our community.
You yourself indicated this afternoon that the intent of this extension is to preserve the waiver and that it can be amended in the future.
We need this time to consider the immediate, short and long term impact of this change and make the right decision for all of us in the name of public health.