COMPA 2025 agenda focuses on Medicaid, NIMBY, and more – Addiction Treatment Forum

Last month the Coalition of Medication-Assisted Treatment Providers and Advocates (COMPA) of New York released its budget and policy agenda for 2025. There is a lot of news swirling around these days, so much that the opioid epidemic has fallen out of the news cycle. But it’s still here, and in fact, in New York, overdose death rates among Blacks have increased five-fold, and quadrupled among Hispanics and Latinos.

In New York City, one individual dies every four hours from an drug overdose, according to a NYC quarterly report from October 2024. The most common substance involved is fentanyl.

Opioid Treatment Programs (OTPs) and Medication-Assisted Treatment (MAT) providers are on the frontlines of fighting the overdose epidemic. This is not the time for NIMBY (not in my backyard) to limit siting of OTPs. 

It’s also not the time to impeded treatment by limiting Medicaid, which pays for the majority of patients in OTPs, which treat not only OUD, but co-occurring mental illness as well. 

There are 126 OTPs in New York serving over 47,600 patients. These essential providers assist those struggling with opioid dependence through MAT, which combines individually tailored behavioral therapy with clinically effective medications. 

But only 35 counties out of 62 in New York State have an OTP.

OTPs are the only providers allowed to dispense methadone for the treatment of opioid use disorder (OUD), and because it has been determined to be more effective than  buprenorphine with high-potency opioids like illicit fentanyl, it needs to be more accessible. 

Of note is the proposal by Governor Kathy Hochul to impose an MCO tax – a tax on managed care organizations. This tax is supposed to increase funding but there is no provision that this funding be used for substance use disorder (SUD) treatment. 

Below are the COMPA recommendations for 2025.

Invest in the workforce with a 7.8% reimbursement increase on rates and contracts

• OTPs and MAT providers are unable to treat patients up to their normal capacity due to a staffing shortage. This investment will reduce staff vacancies, which are currently at an annual statewide average of 20- 30%, and turnover rates which are currently at a 35% annual rate, depending on provider type.

Dedicate revenue from the MCO Tax to SUD and mental health Services

• The MCO tax is expected to raise $3.7 billion, yet per the Executive Budget, none of this funding is intended for SUD and Mental Health providers. New York continues to struggle with an opioid epidemic, while the demand for mental health services is only increasing, yet both systems remain woefully underfunded. A portion of the MCO tax should be dedicated to behavioral health services.

• Medicaid rate increases: Should other sectors of the health care system receive Medicaid rate increases; it is critical for the sake of parity that behavioral health providers receive increases as well. SUD and mental health providers keep people healthy and improve their outcomes by serving as the first line of defense in meeting people’s needs. They prevent people from finding themselves in a crisis situation, which leads to poorer outcomes.   

Reinvest the annual Medicaid MCO underspend in behavioral health services

• A report from the DOH found that “Even with insufficient provider networks, Medicaid Managed Care Organizations (MCOs) are not spending all their allotted premiums on behavioral health services. A review of two MCO funding mechanisms —the Behavioral Health Expenditure Target (BHET) and Medicaid Loss Ratio (MLR) recoveries—shows that MCOs remitted over $220 million in allocated premiums back to the state from 2017 to 2020. This includes $91 million in BHET remittances from 2018 to 2020 and $130 million in MLR remittances from 2017 to 2019.”

Increase investments in SUD outpatient treatment through an add-on rate

• In the interest of treating dual-diagnosed patients in one setting, COMPA recommends establishing an add-on rate for services provided by higher-credentialed, licensed staff.  This will allow for more treatment of dual-diagnosed individuals at SUD programs. For example, the work of a social worker should carry a higher rate given the type of work that can be performed.

Align NYS law with DEA 72-hour rule for dispensing SUD medication

• COMPA supports S.3416 as part of the final FY 2025-26 state budget. This bill builds on chapter 466 of 2024, which partially aligns New York state law with the federal Drug Enforcement Agency’s rule that allows for a 3-day supply of medication to opioid overdose patients when they are transitioning to treatment. Last year’s law allowed this in ERs in hospitals without full-time pharmacies. The bill opens this up to all institutional dispensers and practitioners. Part O of S.3007/A.3007 in the Executive Budget contains similar language.

Address stigma and NIMBYism in the siting of SUD clinics

• Given the severity of the epidemic, it is crucial that more programs are opened, particularly in underserved areas. COMPA supports efforts to help communities and providers decide where programs should be sited, but believes that more education and coordination is necessary. The Executive should put together a comprehensive plan that focuses on the following:      
• Launch a public service campaign on the importance of treatment to community wellbeing, with an emphasis on methadone treatment.
• Hold town hall meetings to engage and inform stakeholders on the current siting process.

Protect against Medicaid work requirements from the federal government

• Given that the new presidential administration could impose work requirements on Medicaid recipients, the State should ensure that existing vocational opportunities for SUD patients count toward this requirement. COMPA supports the $11.4 million in vocational funding that was restored in the Governor’s Executive Budget, after being cut by the Executive in FY 2024-25. Thank you to the Legislature for its support of these programs.

Prevent OTP closures due to Office of the Medicaid Inspector General (OMIG) audits

• COMPA supports passage of S.4486-E (Harckham)/A.6813-C (Paulin), which would reform the Medicaid audit process of the OMIG. 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.

Establish overdose prevention sites S.399-B(Rivera) and A.338-A (Rosenthal)

• COMPA supports this policy as an important part of harm reduction efforts if it is accompanied by protocols to establish connections to treatment. Evidence shows that these programs prevent overdose deaths and play a critical role in combatting the opioid epidemic.

For additional information, please reach out to Allegra Schorr at aschorr@compa-ny.org