Last week, GNYHA submitted a comment letter to the New York State Department of Health (DOH) regarding proposed Medicaid primary care standards. As part of the release of these draft standards, DOH stated that it was considering making them effective as of January 1, 2009. In response to DOH’s request for comments on the feasibility and appropriateness of these draft standards, GNYHA convened a workgroup ambulatory care directors, residency program directors, and planning directors from member hospitals to develop comments and  recommendations on the proposal. GNYHA also requested to meet with DOH to review the comments. In addition to comments on each specific standard, GNYHA made general recommendations regarding the DOH project, principally that DOH coordinate with health care provider associations to disseminate information and promote best practices on better primary care practices. In particular, GNYHA does not believe that statewide standards for the delivery of primary care services should be used in any way for denial of Medicaid payments. The complete comment letter is available on the GNYHA Web site, www.gnyha.org (see member letter bulletin ML-91, dated August 14, 2008).