When Washington Retreats, States Step Up

I’ve just returned from several days in Albany where I spent time with a broad array of key stakeholders including state officials, policymakers, advocates, providers, payers, and more. Given the sea changes coming out of the nation’s capital, being in the State’s capital felt right and necessary.

The center of gravity in health policy has shifted back to the states. In the run-up to the Affordable Care Act (ACA), the action was in Washington. Lawmakers, advocates of all persuasions, and industry groups all focused on shaping and writing the law, and then either working to enact or block it. It squeaked through by the thinnest of margins.

Then the pendulum swung to the states. That’s where most decisions were made, and where the rubber met the road for implementation. Especially for a state like New York that fully embraced the ACA, success was determined locally.

We are repeating that cycle. But this time, states are left to manage deep cuts rather than expanded resources.

Between the massive health care cuts in HR1—the federal budget reconciliation bill—and anti-science leadership at the Department of Health and Human Services, states must now step up and protect public health. I consider HR1 one of the worst pieces of social policy legislation ever enacted. Along with philanthropic partners, we’ve said this law will “deeply harm the health and well-being of the people we serve for a generation. New Yorkers will be poorer, sicker, and hungrier.” I’ve also written on the dangers of vaccine skepticism—particularly when it comes from the federal government.

Now it’s up to the states to respond to and mitigate the harm to the best of their abilities. So far, I’m encouraged by the choices and actions that New York and like-minded states are making.

For starters, New York is taking decisive action to safeguard public health in the face of federal backsliding on vaccines. Governor Kathy Hochul issued an executive order authorizing pharmacists to provide COVID-19 vaccinations to anyone who wants them. This underscores the State’s commitment to keeping science at the center of health care. Building on that leadership, New York has also joined six neighboring states in creating the Northeast Public Health Collaborative, a coalition dedicated to issuing evidence-based vaccine recommendations independent of Washington’s dangerous and misguided policies. These states are protecting communities, preserving trust in vaccines, and upholding the principle that every life saved through vaccination is a victory against misinformation and preventable illness.

New York is also confronting the painful consequences of federal health care cuts with clarity and resolve. The State stands to lose $7.5 billion in funding for the Essential Plan—which provides affordable, comprehensive coverage for about 1.7 million New Yorkers. Faced with no good choices, Governor Hochul’s administration has opted to wind down the waiver that extended coverage to New Yorkers earning between 200–250% of the poverty level. This is the least bad option they could have chosen though it’s hardly painless; roughly 450,000 New Yorkers will be affected. Some will transition to Qualified Health Plans, some may obtain employer-based insurance, and some will lose coverage altogether. New York is doing what strong leadership requires: making hard choices to shield as many people as possible and limit the damage of reckless federal policy.

The road ahead will not be easy. The cuts are deep, and the tradeoffs will only get more painful. But New York has shown it will not shrink from responsibility. By acting swiftly on vaccines and making tough decisions on health coverage, the State is doing what it can in a moment defined by hostile federal policy. The months ahead will test the strength of our institutions and the resilience of our communities. Leadership now means facing hard truths, weighing imperfect options, and keeping people’s health at the center of every decision. That is the challenge New York faces—and the work it must continue to do.

NYHealth Testimony on Implementing Recommendations from the Veterans Advisory Board

NYHealth Senior Program Officer Derek Coy testified in-person at the September 22, 2025, New York City Council Committee on Veterans Meeting on Oversight – Implementing Recommendations from the Veterans Advisory Board.

Good morning, Chair Holden and members of the Committee. My name is Derek Coy, and I am testifying on behalf of the New York Health Foundation (NYHealth). NYHealth is a private, independent, statewide foundation dedicated to improving the health of all New Yorkers—including the more than 133,000 or so veterans who call New York City home. I am also a proud veteran, having served as a Sergeant in the United States Marine Corps.

At NYHealth, we have a long-standing commitment to improving health and mental health outcomes for veterans. Our work includes data-driven initiatives to assess the needs of City and State veteran populations, expand access to and improve the quality of Veterans Treatment Courts (VTCs), and support student veterans. We have partnered with the New York City Department of Veterans’ Services (NYC DVS) and several veteran-focused community organizations, including Mission: VetCheck, Black Veterans for Social Justice, and Team Rubicon to help expand access to services for veterans in the City.

We appreciate the opportunity to provide testimony on implementing recommendations from the New York City Veterans Advisory Board.

We support many of the Board’s recommendations. In particular, we applaud recommendations that promote programs and services connecting veterans to the benefits for which they are eligible, as well as to health and mental health services, housing, education, and other critical supports such as peer-to-peer networks. 

A Focus on Suicide Prevention is Needed

We strongly encourage the Board and the Council to expand the recommendations and adopt an explicit focus on veteran suicide prevention. Our analysis of recent data shows that New York City veterans die by suicide at twice the rate of their civilian counterparts.[1] Other research indicates that certain subgroups, including justice-involved and recently transitioned veterans, are at even higher risk.

Below, we offer several considerations and recommendations, drawn from NYHealth’s expertise and experience in veteran suicide prevention.

Strengthen the Dwyer Veterans Peer Support Program

The report from the Veterans Advisory Board highlights NYC’s recent expansion of the Joseph P. Dwyer Peer Support Program (Dwyer program) and we agree with its recommendation to improve processing of these grants. NYHealth has supported expanding peer support programs statewide, particularly the Dwyer Program. As the report notes, the Dwyer program reduces isolation and connects veterans to services through a variety of approaches, making it a powerful tool for promoting mental health and preventing suicide. The program is ripe for more robust evaluation to support further expansion and replication of the program throughout the City.

Expand Data Collection and Evaluation

Robust program evaluation and data collection are needed to understand what is working, and where more resources are needed. We support the Board’s recommendation to use increased funding to NYC DVS to expand evaluation and documentation of programming.

Over the past decade, NYHealth has funded and partnered with many organizations to evaluate the needs of New York veterans and veteran-serving organizations. For example, in 2019, NYHealth supported the Institute for Veterans and Military Families (IVMF) at Syracuse University to conduct a 50-state analysis of each state’s veteran agencies. This work demonstrated that New York State’s Department of Veterans’ Services, and by extension NYC DVS, is underfunded compared to peer states. New York State also spends less per veteran than almost every other state.[2]

When evaluating programs, such research must include key measures such as veteran suicide rates. For example, the City’s Bureau of Vital Statistic could make available relevant local data to help government and nonprofit organizations improve service delivery. Future research efforts should also disaggregate data by race, ethnicity, age and borough to better inform tailored programs and address disparities in veteran outcomes.

Ensure Veterans Treatment Courts are Inclusive

Justice-involved veterans are twice as likely to attempt suicide compared to veterans who have not encountered the criminal justice system.[3] VTCs are a proven intervention to reduce that risk, in part due to their robust peer support program component.

VTCs are specialized courts that provide justice-involved veterans with access to mental health care, substance use treatment, and peer mentorship, rather than punitive measures alone. NYHealth has been involved in advocacy to build and expand VTCs since their creation in 2008, and spearheaded efforts to support policy change that created universal access statewide in 2021.

We support the report’s recommendation for inclusive eligibility policies that allow all veterans, regardless of discharge status, to access these programs. To strengthen VTCs further, we recommend:
•           Expanding training for peer mentors in cultural competency and suicide prevention;
•           Sharing best practices across courts; and
•           Exploring compensation models to sustain peer mentors.

Support Student Veterans During a Critical Transition Period

Transitioning from military to civilian life can be a particularly vulnerable period. Research shows that the first year after separation, sometimes referred to as the “deadly gap”, carries the highest risk of suicide among younger veterans.[4] Because of their time in service, student veterans are typically older, more likely to have jobs off-campus, and more likely to be parents than students with no military history. These responsibilities, combined with higher rates of psychological symptoms and difficulty navigating academia, can create real barriers. Stigma, limited access to culturally competent care, and confusion around U.S. Department of Veterans Affairs (VA) benefits only compound these challenges.

Suicidal ideation is also significantly higher among student veterans compared with civilian students.[5] And younger veterans (18–34) have the highest rates of suicide among all veteran age groups.[6] Providing comprehensive support, culturally competent care on campus and in communities, along with peer support, is essential for their academic, professional, and personal success.

As someone personally supported by the GI Bill®, I understand the life-changing potential when the right programs and supports are in place. The Board’s report outlines important recommendations, and we recommend additional efforts to address suicide prevention among students, including:

  • Stronger calls to action focused on preventing veteran suicide;
  • Targeted interventions for high-risk groups, including justice-involved veterans and those transitioning from service;
  • More accurate and timely capture and dissemination of local veteran suicide information; and
  • Implementing proven screening tools in more locations that veterans frequent, e.g. the Columbia Screening Protocol.

Conclusion

Thank you again for the opportunity to testify. NYHealth is committed to supporting the City’s efforts to improve services for veterans, which must include suicide prevention focused efforts.

We encourage the Council to regard us as a resource and partner as these efforts continue. You can learn about our veterans’ health work and more by visiting our website, www.nyhealthfoundation.org. If you have any questions or would like to discuss further, please reach out to me at coy@nyhealthfoundation.org. Together, we can ensure that New York City veterans receive the support, care, and opportunities they need to thrive.

References

[1] NYHealth, “Navigating the Crisis: Deaths of Despair and Suicide Among New York City Veterans”, 2024. Accessed September 2025. Available at https://nyhealthfoundation.org/resource/nyc-deaths-of-despair-suicide/#background

[2] Syracuse University, Institute for Veterans and Military Families, “A Strategic Roadmap to Enhance the Role and Impact of the New York State Division of Veterans’ Services”, 2019. Accessed September 2025. Available at: https://nyhealthfoundation.org/wp-content/uploads/2019/07/IVMF-strategic-roadmap-to-enhance-the-role-and-impact-of-ny-state-dvs.pdf

[3] Holliday, R., Forster, J. E., Desai, A., Miller, C., Monteith, L. L., Schneiderman, A. I., & Hoffmire, C. A. (2021). Association of lifetime homelessness and justice involvement with psychiatric symptoms, suicidal ideation, and suicide attempt among post-9/11 veterans. Journal of Psychiatric Research, 144, 455–461. https://doi.org/10.1016/j.jpsychires.2021.11.007

[4] Sokol, Y., Gromatsky, M., Edwards, E. R., Greene, A. L., Geraci, J. C., Harris, R. E., Goodman, M. (2021). The deadly gap: Understanding suicide among veterans transitioning out of the military. Journal of Psychiatry Research. https://doi.org/10.1016/j.psychres.2021.113875.

[5] Lake, K.N., Ferber, L., Kilby, D.J., Mourtada, H., Pushpanadh, S., and Verdeli, H (2022). Qualitative Study Examining Perceived Stigma and Barriers to Mental Health Care Among Student Veterans. Journal of Veterans Studies, 8(3), pp. 239–252. DOI: http://doi.org/10.21061/jvs.v8i3.379.

[6] NYHealth, Data Snapshot: Veteran Suicide in New York State (2022 Update). (2022). New York Health Foundation. Accessed September 2025. Available at: https://nyhealthfoundation.org/resource/data-snapshot-veteran-suicide-in-new-york-state-2022/

NYHealth Comments on CMS’ Medicare Physician Fee Schedule Reform

NYHealth submitted the following comments in support of the Centers for Medicare and Medicaid Services’ (CMS) proposed rule to reform the Medicare Physician Fee Schedule (PFS) by modernizing the methodology for valuing Relative Value Units (RVUs), the basic unit of measurement that determines how much providers are paid for specific services.

September 12, 2025

Dr. Mehmet Oz
Administrator
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244

Subject: Public Comment on CY 2026 Medicare Physician Fee Schedule Proposed Rule
Docket ID: CMS-1832-P
Submitted via: regulations.gov

Re: Revisions to Payment Policies under the Medicare Physician Fee Schedule, Quality Payment Program and Other Revisions to Part B for CY 2026

Dear Administrator Oz,

The New York Health Foundation (NYHealth) appreciates the opportunity to comment on the Centers for Medicare and Medicaid Services’ (CMS) proposed rule regarding the Medicare Physician Fee Schedule (PFS) for Calendar Year 2026. Nearly 3.9 million New Yorkers[1]—almost 20% of the State’s population—are enrolled in Medicare, making CMS policy decisions highly consequential for New Yorkers’ health and wellbeing. Furthermore, Medicare payment policy often sets the pace for private payers.

NYHealth is a private, independent foundation dedicated to improving the health of all New Yorkers. We advance policies and initiatives that strengthen primary care services so New Yorkers can better prevent and manage chronic conditions. This work has provided us with in-depth knowledge of how high-quality primary care systems improve health care access and delivery.

We strongly support CMS’s proposal to reform the Medicare Physician Fee Schedule (PFS) by modernizing the methodology for calculating Relative Value Units (RVUs), the basic unit of measurement that determines how much providers are paid for specific services.

Primary care has long been undervalued in the PFS, where high-value services such as chronic disease management and care coordination are often under-reimbursed or not reimbursed at all. Modernizing RVUs is essential to correcting decades of underinvestment, strengthening the financial foundation of primary care, and improving timely access for patients.

Our nation underinvests in primary care

Primary care is the cornerstone of a strong health care system. It is often a patient’s first and most frequent point of contact with care and is one of the strongest predictors of better health outcomes. Research proves that accessible, high-quality primary care increases preventive care services—such as cancer screenings and flu vaccinations—and improves the management of chronic conditions like diabetes, hypertension, and asthma.[1], [2] The evidence is clear: when primary care is available and accessible, people live longer, healthier lives.

Yet the nation’s primary care system is falling short. In New York State, one in three residents live in a region with inadequate primary care access, with particularly severe shortages in rural communities and communities of color. More than 60% of rural counties in New York State are federally designated as Health Professional Shortage Areas for primary care, dental, and mental health.[3] In predominantly Black neighborhoods, residents are 28 times more likely to live in census tracts with the most pronounced primary care shortages.[4],[5] For many, this means traveling long distances, waiting weeks or months for an appointment, or forgoing routine care altogether.

Primary care saves money. When patients can’t see their regular doctor when they need to, they get sicker and turn to hospitals or emergency rooms, where care is more expensive and more traumatic. The average cost of an ER visit is more than $1,200, compared with about $300 for a primary care visit.[6]

Our health care system is fundamentally out of balance. In the United States, less than five cents of every health care dollar goes toward primary care—even though primary care providers handle one in three health care visits.[7],[8] Increased investment in primary care will reverse decades of underfunding that have fueled provider burnout and workforce shortages.

This regulation is a critical step to correct the systemic undervaluation of primary care

The current valuation approach is flawed. It relies too heavily on limited data sources and fails to capture the full scope of services necessary to deliver high-quality primary care, resulting in inadequate payment.[9]

CMS’s proposed rule is an important step forward. By drawing on a broader range of data sources that better reflect the realities of primary care practice, CMS would modernize its valuation approach. This proposal aligns with recommendations from the National Academies of Sciences, Engineering, and Medicine’s 2025 report, Improving Primary Care Valuation to Inform the Medicare Physician Fee Schedule, which notes that diversifying data sources—including electronic health record logs and other direct-observation data—will “enhance the accuracy, generalizability, and comprehensiveness of payment rate determinations.”[10]

The change will complement state-based efforts to increase investment in primary care

This proposed reform complements state-based efforts to rebalance their health care spending. At least 17 states have adopted policies to prioritize primary care spending,[11] requiring payers to measure, report, and in many cases increase primary care spending.

New York State is taking a similar approach. Policymakers are weighing a proposal requiring health plans to direct 12.5% of total health care expenditures to primary care, and, if necessary, increase spending by 1% annually until the target is met.[12]

State level policy changes have created momentum for rebalancing the health care system. By finalizing this proposed rule, CMS will reinforce and accelerate state efforts. Medicare has the ability to not only invest directly in primary care, but also signal to other payers, including Medicaid and private insurers, to follow suit.

Working together, federal action and state actions can strengthen the primary care system and make Americans healthy.

Conclusion

This reform is necessary and overdue; we strongly encourage CMS to finalize the proposed regulation. The proposal will help reverse the longstanding undervaluation of primary care.

We would be happy to answer questions or share additional insights from our primary care partners in New York State. For more information, please contact Program Officers Ali Foti (Foti@nyhealthfoundation.org) and Victoria Russo (Russo@nyhealthfoundation.org).

Sincerely,

David Sandman, Ph.D.
President and CEO
New York Health Foundation

References

[1] Levine DM, Landon BE, Linder JA. “Quality and Experience of Outpatient Care in the United States for Adults With or Without Primary Care,” JAMA Internal Medicine 2019;179(3):363–372. https://jamanetwork.com/journals/jamainternalmedicine/fullarticle/2721037.

[2] Shi L, “The Impact of Primary Care: A Focused Review,” Scientifica. 2012; 2012:432892. https://pmc.ncbi.nlm.nih.gov/articles/PMC3820521/.

[3] Office of the New York State Comptroller, “The Doctor is…Out. Shortages of Health Professionals in Rural Areas,” https://www.osc.ny.gov/press/releases/2025/08/dinapoli-rural-counties-face-shortage-health-professionals, accessed August 2025.

[4] Brown E, Polsky D, Barbu C, Seymour J, Grande D. “Racial Disparities in Geographic Access to Primary Care in Philadelphia,” Health Affairs 2016; 35(8). https://www.healthaffairs.org/doi/10.1377/hlthaff.2015.1612.

[5] “Predominantly Black neighborhoods” are census tracts where 80 percent of residents or more identify as African American.

[6] Agency for Health Care Research and Quality. “Information on the health status of Americans, health insurance coverage, and access, use, and cost of health services: Medical Expenditure Panel Survey (MEPS) Household Component (HC),” n.d., https://datatools.ahrq.gov/meps-hc/?tab=use-expenditures-and-population&dash=12, accessed February 2025.

[7] Patient-Centered Primary Care Collaborative, “Investing in Primary Care: A State-Level Analysis,” July 2019.

https://www.pcpcc.org/sites/default/files/resources/pcmh_evidence_report_2019_0.pdf.

[8] National Academies of Sciences, Engineering, and Medicine, Implementing High-Quality Primary Care: Rebuilding the Foundation of Health Care, Washington, DC: The National Academies Press, May 2021. https://www.nationalacademies.org/our-work/implementing-high-quality-primary-care#sectionPublications.

[9] Ibid.

[10] National Academies of Sciences, Engineering, and Medicine. (2025). “Improving Primary Care Valuation Processes to Inform the Physician Fee Schedule.” https://www.nationalacademies.org/our-work/improving-primary-care-valuation-decisions-for-the-physician-fee-schedule-by-the-center-for-medicare.

[11] Primary Care Development Corporation. (2024). State Trends Investment Update. https://www.pcdc.org/wp-content/uploads/2025-PCDC-Primary-Care-Update.pdf

[12] New York State Senate Bill 2025-S1634. (2005). https://www.nysenate.gov/legislation/bills/2025/S1634

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