Author: teamnyshealth

NYHealth President and CEO David Sandman submitted the following testimony on February 20, 2026, to the New York State Joint Legislative Public Hearing on the 2026 Executive Budget Proposal: Higher Education.

Thank you, Chair Krueger, Chair Pretlow, and members of the Senate Finance and Assembly Ways and Means Committees. I am pleased to provide testimony 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, especially people of color and others who have been historically marginalized.

Across the State, many New Yorkers wait weeks or months to see a primary care clinician. By the time they do, they are often sicker and harder to treat. This reflects a health care system that is out of balance, shaped by chronic underinvestment in primary care. Nationally, less than 5 cents of every health care dollar goes to primary care clinicians, even though they handle one in three health care visits. ^[1],[2] The same troubling pattern holds true in New York.^[3]

New York’s underinvestment in primary care has contributed to a shortage of health care workers. Clinician shortages and strain, combined with the fast growth of the Medical Assistant (MA) workforce, have meant that MAs sometimes take on enhanced roles in patient care. In this time of impending federal cuts, providers are looking to MAs to contribute even more, but barriers stand in the way of unlocking their full potential. In New York, MAs are neither licensed nor defined by a scope of practice. New York State provides little guidance beyond a memo outlining what MAs cannot do.^[4] Notably, New York is the only state that does not permit MAs to administer vaccines, even with appropriate training and supervision.^[5],[6]

Solving the workforce shortage will not be easy, but there are practical steps we can take now. One immediate, common-sense solution is to allow medical assistants (MAs) to vaccinate patients, easing the burden on clinicians.

MAs Are Trusted Bridges Between Patients and Clinicians

MAs are vital members of the primary care team, responsible for administrative tasks and certain clinical duties under the supervision of a physician or other clinician.^[7] MAs bring important skills to primary care teams, including collecting essential health information, supporting preventive care, reinforcing patient education, and ensuring care is culturally and linguistically accessible.^[8]

New York employs approximately 40,000 MAs, the fourth-highest number of any state.^[9] The number of MAs in New York is expected to rise by 27% between 2022 and 2032, outpacing many other health occupations.^[10] Due to this anticipated growth, it is particularly important that policies enable MAs to practice in ways that most effectively support care delivery and alleviate workforce shortages.

MAs are a trusted bridge between clinicians and patients, particularly in underserved and marginalized communities. They are often among the first and most consistent points of contact for patients, helping to improve access, communication, and quality of care.^[11] MAs are also predominantly people of color and part of the communities they serve, making them uniquely positioned to build relationships with patients and earn their trust.^[12] For instance, four out of five MAs in New York provide language translation services to patients, according to NYHealth-supported research.^[13] Care teams that use MAs beyond administrative and basic clinical duties

often see improvements in patients’ use of health services and health outcomes;^[14],[15]improved clinical quality metrics and operational efficiencies;^[16],[17] and reductions in provider strain and burnout.^[18] In short, MAs are capable of—but currently underutilized in—supporting equitable and high-quality patient care.

New York Is Falling Behind Other States at a Time It Can’t Afford To

New York lags other states in making the most of MAs’ potential. At present, New York is the only state that does not allow clinicians to delegate the task of administering injections, like vaccinations, to MAs, with appropriate training and supervision.^[19],[20] The COVID-19 pandemic made clear the effects of this limitation when New York’s resources were strained in the face of a massive effort to administer COVID vaccines.^[21] New York will be feeling the effects again, as federal changes to immunization guidelines put more burden on doctors to counsel parents and patients on vaccine decisions. Every minute counts in a short primary care visit, and MAs can and should take on the task of administering vaccines after the supervising clinician and patient have discussed need and safety.

The Executive Budget proposal includes a common-sense provision for New York to join all other states by allowing trained MAs to administer vaccinations under the supervision of a physician, nurse practitioner, or physician assistant.

Further affirming the importance of this issue, the New York State Legislature introduced a bill (A5460C/S5340B) to formally authorize MAs to administer vaccines with the appropriate training and supervision from a physician, nurse practitioner, or physician assistant. The bill was passed in the Senate in June 2025. This policy change would expand the pool of health professionals available to vaccinate New Yorkers, alleviating strain on clinicians and allowing them to focus on more complex patient care needs.

Providers are Ready to Put This Policy Into Practice

New York health care providers are ready to support MAs’ expanded roles and implement this proposed policy change. A recent NYHealth-supported survey of primary care practice administrators and MA supervisors across New York found that:

• 2 out of 3 primary care providers surveyed would likely have their MAs perform vaccinations if permitted.
• That proportion increases to 8 in 10 providers surveyed among Federally Qualified Health Centers, New York’s safety net primary care providers.
• 85% of practice administrators surveyed said they would train their MAs to vaccinate in-house, supporting the feasibility of implementing this policy change.^[22]

These findings align with direct feedback from primary care teams across New York. One practice administrator noted, “The ability for our MAs to do injections would really take extra stress off our nursing staff, who [are] expected to work with one provider in addition to needing to be available for the MAs to request injections.”^[23] Nurses engaged in statewide focus groups largely echoed the opportunity for efficiency and reduced nursing strain by allowing MAs to administer certain vaccines, especially flu shots, if adequately trained and supervised. One nurse said: “If I can wave my magic wand and have one of my MAs who was trained to administer flu vaccines, that will help eliminate half of the back[log] of patients that are coming in and scheduling just for a flu vaccine. I mean, that would just be a huge check.”^[24] Similarly, an MA shared their frustration with the status quo: “We can draw blood. We can do everything else but the vaccine administration. We cannot do [vaccines], but 15 minutes away [in Pennsylvania], those MAs are able to, and they have had the exact same training as us.”^[25]

There is no single, quick solution to New York’s workforce shortage. However, expanding the role of MAs is an immediate, common sense, and widely supported step.
Conclusion
A high-performing health system depends on a strong primary care workforce. MAs are ready to do more, but outdated restrictions prevent them from taking on more. Expanding the role of MAs, including authorizing supervised vaccine administration, will expand access and get care to New Yorkers faster.

 

[1] Chang J, Silva Gordon B, Desouza C. 4% of Health Spending Goes to Primary Care. Health Care Cost Institute. 2025. Available at: https://healthcostinstitute.org/hcci-originals-dropdown/all-hcci-reports/4-of-health-spending-goes-to-primary-care.

[2] Jabbarpour Y, Petterson S, Jetty A, Byun H. The Health of US Primary Care: A Baseline Scorecard Tracking Support for High-Quality Primary Care. 2023. Milbank Memorial Fund. Available at:  https://www.milbank.org/wp-content/uploads/2023/02/Milbank-Baseline-Scorecard_final_V2.pdf.

[3] Milbank Memorial Fund. Primary Care Scorecard. 2025. https://www.milbank.org/primary-care-scorecard/, accessed February 2026.

[4] New York State Education Department. Medical Assisting. https://www.nysed.gov/career-technical-education/medical-assisting, accessed February 2026.

[5] American Association of Medical Assistants. State Scope of Practice Laws.https://www.aama-ntl.org/docs/default-source/state-sop-laws/new-york-state-opinion-utilization-of-medical-assistants-june-2023.pdf?sfvrsn=e7fe6ba1_1, accessed February 2026.

[6] Balasa DA. State Injection Laws for Medical Assistants. 2023. Available upon request.

[7] U.S. Bureau of Labor Statistics. Occupational Employment and Wages, May 2023: 31-9092 Medical Assistants. https://www.bls.gov/oes/current/oes319092.htm, accessed February 2025.

[8] Foti A, Okonkwo C, Ford MM, Cobbs E, Havusha, A., Sandman, D. 2025. Profile of Medical Assistants Across Primary Care Practice Settings. New York Health Foundation. New York, NY.

[9] U.S. Bureau of Labor Statistics, “Occupational Employment and Wages, May 2023: 31-9092 Medical Assistants,” https://www.bls.gov/oes/2023/may/oes319092.htm, accessed February 2025.

[10] New York State Department of Labor. Long-term Occupational Projections.https://dol.ny.gov/long-term-occupational-projections, accessed January 2025.

[11] Foti A, Okonkwo, C. Ford, MM., Cobbs, E. Havusha A, Sandman D. 2025. Profile of Medical Assistants Across Primary Care Practice Settings. New York Health Foundation. New York, NY.

[12] U.S. Census Bureau. ACS 1-Year Estimates Public Use Microdata Sample. Race demographics available at https://data.census.gov/app/mdat/ACSPUMS1Y2021/table?cv=RAC1P&rv=ucgid,OCCP(3645)&wt=PWGTP&g=AwFm-BVBlBmA2IA, ethnicity demographics available at https://data.census.gov/app/mdat/ACSPUMS1Y2021/table?rv=SOCP(319092),HISP,ucgid&wt=PWGTP&g=AwFm-BVBlBmA2IA, accessed February 2026.

[13] Fitzhugh Mullan Institute for Health Workforce Equity. Survey Results: The Medical Assistant Role in Primary Care. George Washington University. 2025. Available at: https://publuu.com/flip-book/319048/2330798.

[14] Willard-Grace R, Chen EH, Hessler D, DeVore, Prado C, Bodenheimer T, Thom DH. (2015). Health Coaching by Medical Assistants to Improve Control of Diabetes, Hypertension, and Hyperlipidemia in Low-Income Patients: A Randomized Controlled Trial. The Annals of Family Medicine, 13 (2).

[15] Rodriguez HP, Friedberg MW, Vargas-Bustamante A, Chen X, Martinez AE, Roby DH. The impact of integrating medical assistants and community health workers on diabetes care management in community health centers. BMC Health Services Research. 2018, 18(875).

[16] Shaw JG, Winget M, Brown-Johnson C, Seay-Morrison T, Garvet DW, Levine M, Safaeinili N, Mahoney MR.  Primary Care 2.0: A Prospective Evaluation of a Novel Model of Advanced Team Care With Expanded Medical Assistant Support. Annals of Family Medicine. 2021, 19(5):411-418.

[17] Wagner EH, Flinter M, Hsu C, Cromp DA, Austin BT, Etz R, Crabtree BF, Ladden MJD. Effective team-based primary care: observations from innovative practices. BMC Family Practice 2017, 18(13).

[18] Sinsky CA, Willard Grace R, Schutzbank AM, Sinsky TA, Margolius D, Bodenheimer T. In Search of Joy in Practice: A Report of 23 High-Functioning Primary Care Practices.Annals of Family Medicine 2013; 11(3):272—278. 10.1370/afm.1531.

[19] American Association of Medical Assistants. State Scope of Practice Laws. https://www.aama-ntl.org/docs/default-source/state-sop-laws/new-york-state-opinion-utilization-of-medical-assistants-june-2023.pdf?sfvrsn=e7fe6ba1_1, accessed February 2026.

[20] Balasa, DA. State Injection Laws for Medical Assistants. 2023. Available upon request. Accessed January 2026.

[21] Dan Krauth. ‘Unacceptable’: Elected leaders dropped ball on vaccine rollout in Tri-State, critic says. ABC 7 NY. https://abc7ny.com/post/7-on-your-side-investigates-vaccine-rollout-ny-covid/9598124/, accessed February 2026.

[22] Fitzhugh Mullan Institute for Health Workforce Equity. Survey Results: The Medical Assistant Role in Primary Care. George Washington University. 2025. Available at: https://publuu.com/flip-book/319048/2330798.

[23] Reference available upon request.

[24] Reference available upon request.

[25] Fitzhugh Mullan Institute for Health Workforce Equity. 2025. Medical Assistants in New York: Focus Group Findings. George Washington University. 2025. Available at: https://publuu.com/flip-book/319048/2330794.

February 17, 2026

The Honorable Robert F. Kennedy, Jr.
Secretary
U.S. Department of Health and Human Services
200 Independence Avenue SW
Washington, DC 20201

Subject: Public Comment on Proposed HHS Rules Affecting Access to Gender-Affirming Care
Docket ID: CMS–3481–P and CMS–2451–P
Submitted via: regulations.gov

Re: Notice of Proposed Rulemaking: Medicare and Medicaid Programs; Hospital Condition of Participation: Prohibiting Sex-Rejecting Procedures for Children and Medicaid Program; Prohibition on Federal Medicaid and Children’s Health Insurance Program Funding for Sex- Rejecting Procedures Furnished to Children

The New York Health Foundation (NYHealth) appreciates the opportunity to submit comments on the Department of Health and Human Services’ (HHS) proposed rules affecting access to gender-affirming care.

NYHealth is a private foundation that works to improve the health of all New Yorkers and advance health equity. We offer these comments to underscore the importance of ensuring continued access to evidence-based, medically necessary care for all patients, including transgender and gender-diverse children.

The proposed rules would eliminate federal Medicaid funding for gender-affirming care services for minors in all provider venues and prohibit hospital participation in Medicaid and Medicare if they perform these services. Using government reimbursement to enforce compliance, the proposed rules erode provider autonomy, threaten the delivery of patient-centered care, and risk averse public health outcomes.

Gender-Affirming Care Is Evidence-Based, Patient-Centered, and Lifesaving

Leading medical organizations, including the American Academy of Pediatrics (AAP), recognize gender-affirming care as a medically necessary component of comprehensive health care for young patients.^{[1] [2]} They emphasize that health care providers rely on established standards of care and clinical judgment and that treatment decisions should be made through shared decision-making among patients, families, and clinicians, guided by evidence and individual circumstances.[3] Restrictions that override clinical expertise with government policy directives threaten the delivery of high-quality, patient-centered care and interfere with patient–provider relationships.

Moreover, preserving access supports continuity of care, helping patients avoid preventable adverse outcomes and supporting long-term health. For many children, timely access to gender-affirming care is closely linked not only to physical health, but also to psychological safety, stability, and reduced risk of crisis. For example, disruptions in care may have significant consequences for mental health, particularly for youth already experiencing high rates of stress, stigma, and elevated suicide risk. A growing body of peer-reviewed research demonstrates that gender-affirming care is associated with improved mental health outcomes and reduced risk of depression, anxiety, self-harm, and suicidality among transgender and gender-diverse individuals, including during adolescence. In fact, recent longitudinal research published in the Journal of Adolescent Health found that access to gender-affirming medical care was associated with significantly lower rates of depression and suicidality among youth receiving care over time.[4]

Restricted Access Will Impact Public Health and Health System Performance

The proposed rules will limit access to medically necessary care, particularly for youth who already face significant barriers to services. Access restrictions could delay other treatment—including for children managing chronic diseases—increasing the risk that preventable conditions worsen and result in costlier care, including emergency room visits. Legal advocacy organizations have also cautioned that restrictive policies contribute to heightened distress, fear, and instability for transgender youth and their families, compounding existing mental health challenges and the risk of crises.[5]

Uncertainty and fear about eligibility and coverage may discourage families from seeking care altogether, even for unrelated health needs, undermining trust in health systems and providers. These impacts will reverberate across the broader public health and health system, as delayed access to preventive and outpatient care often results in more intensive interventions later on.

Recommendations

We respectfully urge HHS to:

1. Rescind the proposed rules that would restrict access to gender-affirming care by eliminating federal Medicaid funding for services for minors and placing hospital participation in Medicaid or Medicare at risk if they perform these services.
2. Affirm the role of clinical expertise and evidence-based standards of care in guiding medical decision-making for transgender and gender-diverse patients.
3. Ensure that federal health policy supports access to medically necessary care and promotes positive health outcomes for all individuals.

We appreciate the opportunity to provide comments. We encourage HHS to uphold policies that support medically-necessary care and safeguard patient-provider relationships. For questions regarding this submission, please contact Victoria Russo at russo@nyhealthfoundation.org or (212) 584-7684.

Respectfully,

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

References

[1] Schweikart, Scott J., What’s Wrong With Criminalizing Gender-Affirming Care of Transgender Adolescents?, AMA Journal of Ethics (June 2023). https://journalofethics.ama-assn.org/sites/joedb/files/2023-05/hlaw2-2306.pdf

[2] American Medical Association, Health Insurance Coverage for Gender-Affirming Care of Transgender Patients: Talking Points (2019). https://www.ama-assn.org/system/files/2019-03/transgender-coverage-talking-points.pdf

[3] American Academy of Pediatrics. AAP Opposes New HHS Rules Restricting Access to Care for Families. 2025.
https://www.aap.org/en/news-room/news-releases/aap/2025/aap-opposes-new-hhs-rules-restricting-access-to-care-for-families/

[4] Tordoff, D. M., et al. Mental Health Outcomes in Transgender and Nonbinary Youths Receiving Gender-Affirming Care. Journal of Adolescent Health, 2024.
https://www.jahonline.org/article/S1054-139X(24)00439-7/fulltext

[5] Lambda Legal. Lambda Legal Condemns Trump Administration’s Latest Attack on Trans Youth. December 18, 2025.
https://lambdalegal.org/newsroom/us_20251218_ll-condemns-trump-admin-latest-attack-on-trans-youth/

NYHealth President and CEO David Sandman testified at the New York State Joint Legislative Budget Hearing: Health on February 10, 2026. In his testimony, he addressed the opportunity for New York to make pragmatic, high-impact changes that strengthen the foundation of our health care system and prepare the State for the impending strain posed by federal policies. Investing in primary care, modernizing team-based care by allowing medical assistants to administer vaccines, and safeguarding essential health and nutrition data are concrete actions that improve access and help control costs over time. 

(The recording of Dr. Sandman’s oral testimony at the hearing is available here.)

Thank you, Chair Krueger, Chair Pretlow, and members of the Senate Finance and Assembly Ways and Means Committees, for the opportunity to testify. The New York Health Foundation (NYHealth) is a private, independent, statewide foundation dedicated to improving the health of all New Yorkers, especially people of color and others who have been historically marginalized. As New York battles federal policy retrenchments, funding cuts, and data blackouts, leaders must invest in the core health care systems that safeguard New York’s commitment to health. That means strengthening primary care, modernizing team-based care to meet workforce demands, and ensuring the State has reliable data to guide smart, targeted investments. New York leaders should:

• Prioritize primary care and rebalance health care spending to save on overall health costs;
• Allow medical assistants to administer vaccinations, thus easing the growing burden on doctors and nurses;
• Establish regular, State-led collection and public reporting of food insecurity data to inform health and nutrition policies and investments

Investing in Primary Care: The Smartest Way to Improve Health and Control Costs

Primary care is where most New Yorkers first seek care, manage chronic conditions, and receive preventive services. Despite its proven value, we underinvest in primary care. In the United States, less than five cents of every health care dollar goes to primary care, even though primary care doctors and nurses handle one out of every three health care visits.^{[1] [2]}

The same imbalance is true in New York State. Several analyses of primary care spending data show that primary care receives only 3-5% of New York’s total health spending, well below the 10–12% recommended by national experts and seen in other high-income countries.^{[3] [4] [5] [6]} And both nationally and in New York, primary care’s share of total spending has declined in recent years.^{[7] [8]} The claim that New York lacks a baseline on primary care spending is incorrect and should no longer be used to delay action. This underinvestment leaves families without timely preventive care; increases health care costs; and strains a system that should be keeping New Yorkers healthy, not just treating them—at a higher cost—when they’re sick.

This mismatch in where we devote our health dollars means that despite spending more than $300 billion annually on health care—well above the national average—New York’s health outcomes are only average.^{[9] [10]} When New Yorkers, especially people of color and people living in rural areas, have to wait weeks or months to see their primary care doctor, they end up sicker and are forced to turn to hospitals or emergency rooms (ER), where care is more expensive.^[11] The average cost of an ER visit is $1,200, which is four times what it costs for a primary care visit ($300).^[12] These avoidable emergency room visits and hospitalizations for chronic conditions cost the State billions of dollars each year. ^{[13] [14]}

The solution is not to spend more; we should require health insurance companies to prioritize spending on primary care to rebalance health care spending. Allocating a greater percentage of what we spend to primary care is a more effective way to spend health care dollars and improve its value for people and return on investment.

The Legislature has already recognized the urgency of this issue. Last session, Senator Rivera and Assemblymember Paulin introduced the Primary Care Investment Act (S1634/A1915A) that would require health insurers that spend less than 12.5% of their overall spending on primary care to gradually increase their spending (1% per year) until they reach the 12.5% threshold. It also requires a standard definition of primary care, annual measurement, and public reporting. Last year, S1634 passed the Senate. The same bill is currently pending in the Assembly Insurance Committee.

New York cannot afford to fall further behind. More than 20 states have adopted primary care investment policies that are already improving access and controlling costs. California’s decision to set a 15% spending target further demonstrates that New York’s goal of 12.5% is a pragmatic and practical step forward.

Oregon found that every additional $1 invested in primary care saved $13 in emergency, specialty, and hospital services.^[15]

Massachusetts reported that provider organizations investing more in primary care delivered higher-quality care while spending less on inpatient and outpatient hospital services.^[16]

Rhode Island demonstrated that increasing primary care investment expanded the number of practicing primary care providers, helping to address shortages and quality.^[17]

National evidence showed that a $10 increase in Medicaid provider reimbursement per primary care visit reduces reports of providers not taking new patients by 13%.^[18]

New findings from a New York-specific analysis and simulation modeling of commercial insurance claims show that targeted primary care delivery could drive meaningful cost savings, especially for higher risk individuals. In one model scenario, if high and medium-high risk enrollees are given two additional primary care visits, total spending is projected to fall by $26 Per Member Per Year (PMPY) in the first year and $79 PMPY in the following year. If similar targeted delivery is modeled statewide among commercially insured New Yorkers, total costs could be reduced by an estimated $248 million in the first year and $753 million in the second year.^[19]

New York should follow evidence demonstrating the value of primary care and require insurance companies to prioritize spending on primary care. That is how we will increase access, improve health outcomes, and save precious dollars.

Allowing Medical Assistants to Vaccinate: A Common-Sense Workforce Solution

Investing in primary care is a fundamental—but not the only—way to enhance patients’ access to primary care and strengthen providers’ ability to provide quality care. Addressing workforce shortages and provider strain is also critical. One immediate, practical solution is to expand the role of medical assistants (MAs).

MAs are vital members of the primary care team, responsible for a range of administrative tasks and certain clinical duties under the supervision of a doctor or other clinician.^[20] As one of the fastest-growing health care professions, the number of MAs in New York is expected to rise by 27% between 2022 and 2032, outpacing many other health occupations.^[21] Care teams that use MAs beyond administrative and basic clinical duties often see improvements in patients’ use of health services and health outcomes;^[22][23] improved clinical quality metrics and operational efficiencies;^{[24] [25]} and reductions in provider strain and burnout.^[26] MAs are also predominately people of color and often live in the communities they serve, making them uniquely positioned to build relationships with patients and earn their trust.^[27] In short, MAs are capable of—but currently underutilized in—supporting equitable and high-quality patient care.

Yet New York is the only state that does not allow clinicians to delegate the task of administering injections, like vaccinations, to MAs, with appropriate training and supervision.^{[28] [29]} The COVID-19 pandemic made clear the effects of this limitation, as New York was strained to administer COVID vaccines.^[30] New York will be feeling the effects of this limitation again now that federal changes to immunization guidelines put more strain on doctors to counsel parents and patients on vaccine decisions. Every minute counts in a short primary care visit, and MAs can and should take on the task of administering vaccines after the doctor and patient have discussed their need and safety. Permitting MAs to administer vaccinations will increase the number of health professionals available to vaccinate New Yorkers and save time for clinicians to focus on more complex patient care needs.

The Executive Budget proposal includes a common-sense provision for New York to join all other states by allowing trained MAs to administer vaccinations under the supervision of a physician, physician assistant, or nurse practitioner.

Evidence from NYHealth-supported research confirms support for this proposal among providers.^[31] A recent survey of primary care practice administrators and nurse supervisors of MAs across New York reveals that 2 out of 3 primary care providers would likely have MAs perform vaccinations, if permitted. Among Federally Qualified Health Centers, New York’s safety net primary care providers, that proportion increases to 8 out of 10 providers. And, 85% of practice administrators said they would train MAs to vaccinate in-house, suggesting this policy would largely not be burdensome to adopt.

There is no quick fix to solve New York’s workforce shortage, but enhancing the role of MAs is an immediate, common-sense, and widely supported step.

Ensuring Data to Guide Health and Nutrition Investments in New York

As the Executive Budget seeks to strengthen primary care and improve health, it must also safeguard the data infrastructure that allows the State to track trends over time, assess how programs are performing, and target investments effectively. One urgent gap is the loss of reliable, New York-specific data on food insecurity, a core driver of health outcomes.

For decades, policymakers, researchers, and advocates have relied on federal data from the U.S. Department of Agriculture’s (USDA) Household Food Security Survey to understand the scale of food insecurity across states. This year, the USDA announced it will no longer survey and publish state-level food insecurity estimates, leaving New York with a critical data gap.^[32]

Consistent access to nutritious food is essential for optimal health and wellbeing.^[33] Food insecurity has been on the rise in New York since the COVID-19 pandemic. Between 2022 and 2024, 14% of households in New York State were food insecure compared with 10.3% from 2019–2021—a 36% increase and above the national average.^{[34] [35] [36]}

At the same time, new federal changes to programs like the Supplemental Nutrition Assistance Program (SNAP) and Medicaid, including work requirements and more frequent recertifications, will likely lead to disruptions in enrollment and higher food insecurity. Data and evidence are essential to inform and drive State action in response.

In the face of federal retrenchment, New York can step in to fill this gap by directing the State Department of Health to regularly collect and publicly report on food insecurity data using existing data collection infrastructure.

One viable solution is to include a brief food security module in the annual Behavioral Risk Factor Surveillance Survey, leveraging the State Department of Health’s existing data infrastructure at little or no cost. The module could mirror the USDA’s six item U.S. Household Food Security Survey to ensure data continuity with federal data collection. To support this approach, two bills have been introduced (A9168/S8553) directing the Department of Health to report annually on food security trends across New York.

Establishing State-led food security data collection and a publication would allow for timely analysis and support evaluation of nutrition assistance programs. Annual reporting will equip policymakers with up-to-date data to understand the needs of New Yorkers, particularly for families with children and communities of color who experience disproportionately high rates of hunger.^[37]

Conclusion: Opportunities to Improve New York’s Health in the Face of Federal Threats

New York has an opportunity to make pragmatic, high-impact changes that strengthen the foundation of our health care system and prepare the State for the impending strain posed by federal policies. Investing in primary care, modernizing team-based care by allowing medical assistants to administer vaccines, and safeguarding essential health and nutrition data are concrete actions that improve access and help control costs over time.

By prioritizing these changes, New York can build stronger, healthier communities and ensure that all New Yorkers get the care and support they need, when they need it. We appreciate your leadership on these issues and look forward to working together to advance these shared goals.

 

[1] Chang J, Silva Gordon B, Desouza C. 4% of Health Spending Goes to Primary Care. Health Care Cost Institute. 2025. Available at: https://healthcostinstitute.org/hcci-originals-dropdown/all-hcci-reports/4-of-health-spendinggoes-to-primary-care

[2] Jabbarpour Y, Petterson S, Jetty A, Byun H. The Health of US Primary Care: A Baseline Scorecard Tracking Support for High-Quality Primary Care. 2023. Milbank Memorial Fund. Available at: https://www.milbank.org/wp-content/uploads/2023/02/Milbank-Baseline-Scorecard_final_V2.pdf.

[3] Chang J, Silva Gordon B, Desouza C. 4% of Health Spending Goes to Primary Care. Health Care Cost Institute. 2025. Available at: https://healthcostinstitute.org/hcci-originals-dropdown/all-hcci-reports/4-of-health-spending-goes-to-primary-care.

[4] Phillips RL Jr., Basemore AW. Primary Care And Why It Matters For U.S. Health System Reform. HealthAffairs. May 2010: 29(5). Available at: https://www.healthaffairs.org/doi/pdf/10.1377/hlthaff.2010.0020

[5] Milbank Memorial Fund. (2025). Primary Care Scorecard. https://www.milbank.org/primary-care-scorecard/, accessed February 2026.

[6] Jabbarpour Y, Petterson S, Jetty A, Byun H. The Health of US Primary Care: A Baseline Scorecard Tracking Support for High-Quality Primary Care. 2023. Milbank Memorial Fund. Available at: https://www.milbank.org/wp-content/uploads/2023/02/Milbank-Baseline-Scorecard_final_V2.pdf.

[7] Chang J, Silva Gordon B, Desouza C. 4% of Health Spending Goes to Primary Care. Health Care Cost Institute. 2025. Available at:
https://healthcostinstitute.org/hcci-originals-dropdown/all-hcci-reports/4-of-health-spending-goes-to-primary-care.

[8] Milbank Memorial Fund. (2025). Primary Care Scorecard. https://www.milbank.org/primary-care-scorecard/, accessed February 2026.

[9] New York State Division of Budget. Health Care Briefing Book FY2025. 2024. Available at: https://www.budget.ny.gov/pubs/archive/fy25/ex/book/healthcare.pdf.

[10] America’s Health Ranking. Overall in New York. United Health Foundation. 2024. https://www.americashealthrankings.org/explore/measures/Overall/NY, accessed December 2025.

[11] Jabbar ABA, Talha KM, Nambi V, Abramov D, and Minhas AMK. Primary Care Physician Density and Mortality in the United States. Journal of the National Medical Association 116, no. 5 (2024): 600–606. https://doi.org/10.1016/j.jnma.2024.10.001.

[12] Ford, MM. Allard, A. Cobbs, E. Sandman, D. Cohen, L. 2026. “The State of Primary Care in New York: 2025 Data Update” New York Health Foundation and Primary Care Development Corporation. New York, New York

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