SPG is pleased to announce that we are assembling a new team to conduct Health Equity Impact Assessments (HEIAs) for Certificate of Need (CON) applications in New York. Our HEIA team combines SPG’s unmatched knowledge of New York State health policy and government affairs with the expertise of leading independent consultants and researchers in population health, health equity, and anti-racism.
New York’s requirement is the first that has been passed by any state, and we know many organizations are still working to understand the process. SPG is committed to a flexible approach tailored to each individual project, large or small. From constructing a new inpatient unit to relocating a community clinic, we will consider all projects on their own terms, in the context of their local communities and needs.
Below and attached is further information on HEIAs and how SPG will approach conducting them – please reach out at any time to discuss.
Our Approach to HEIAs
New York’s new HEIA requirement applies to licensed Article 28 health care entities – hospitals, nursing homes, and licensed clinics, including Federally Qualified Health Centers – who are embarking on major construction and other capital projects. In general, if a proposed CON project will close, substantially reduce, or move services, the application must include an independently conducted HEIA.
The HEIA will describe the potential health equity impacts of a project on the underserved populations in the applicant’s community and identifies how it could help or harm their access to and quality of care. Once complete, the HEIA will be publicly posted and considered by the Public Health and Health Planning Council (PHHPC) and the Department of Health when evaluating the CON.
Our approach to the HEIA process is based on three major principles:
- We will combine SPG’s unique perspective with attention to local detail.As a firm, SPG is distinctive because we take a stance on policy. SPG’s extensive background in health care policy in New York informs our perspective on how CON projects can improve care and on which aspects should be changed.
SPG is working in partnership with a team of independent experts in anti-racism, community engagement, and health equity. Together, we will conduct ongoing community outreach, perform extensive research and data analysis, and bring decades of experience to the mission of understanding a project’s impact locally as well as in the “big picture” of New York health care.
- We will use data in the HEIA process as a tool for the applicant, the community, and the State to get ahead of potential outcomes. New York’s goal for the HEIA is to gain an understanding of the potential impacts of a CON project, including unintended impacts. As such, the HEIA assessor must conduct a thorough review of data on the local community, including demographics, provider landscape, market share, and more. While we will meet all required data components for the HEIA, we also know that extensive data reviews can produce overwhelming amounts of information without a clear idea of what can and should be done.
SPG will focus on ensuring that our data review process illuminates the project’s top actionable priorities wherever these exist. Such priorities must be clearly identifiable needs, tied to one or more specific underserved populations which may be impacted by the project, which can be prevented or mitigated in advance. Our goal is to reduce the burden on the applicant while averting negative and unintended community impacts.
- We believe the HEIA is fundamentally a chance to take a new approach to engaging with communities. Although the HEIA is a new requirement, it is not necessarily a new burden. Instead, it is an opportunity for providers to conduct truly meaningful stakeholder engagement. Many worthy health care projects have faced community resistance or opposition due to worries about potential negative impacts.
SPG will use the HEIA process to facilitate cooperative, non-adversarial engagement between providers, communities, and other stakeholders. We will use the independent role of the assessor to mediate concerns and work collaboratively towards positive resolutions.