ALBANY UPDATES: COLA, BIP, SH ENHANCEMENTS, GENERAL ADVOCACY

Hi everyone – The following is a summary of what we learned about the COLA, BIP and SH enhancements. Although it will not give you all that you need to know, it should be enough to allow you to start to formulate budgets for the coming year.  OMH has used CFR and CAIRS data, depending on the program type, to work all of this out, which means that accurate reporting on CFRs and in CAIRS is very important.  The additional, promised 2% COLA that is supposed to start in April will extend to clinical workers so that clinic and PROS programs will see a larger impact then.   However, this is a promise that must survive the regular budget process – the governor has to put it in his executive budget and the two houses have to agree or, if the governor does not put it in his executive budget, the advocates will have to work to get the two houses to insist on it in the negotiations.  That said, DOB sent the “call letter” to the state agencies informing them that they must bring in a budget with no increases, while they must find the money for mandatory increases to state personnel costs.  It will be a challenge.  

COST OF LIVING ADJUSTMENT (COLA):

  • Every provider will have to sign a high level attestation that they will use the money as intended.  If that attestation is not received, they will take the money back.  
  • Supported Housing:
    • The COLA will result in a $15 to $25 increase in the regional, annual rates – that is PER YEAR PER BED.  The higher amounts will be in the geographic regions that have higher rates now. They will send the actual amounts out in about a month – they have to go through multiple levels of state approvals.   
    • They will not make provider specific changes.
    • I know it is not a lot but we continue to make the case for stipend increases outside of the COLA – we think we may make some progress on that front again this coming budget cycle.  We will keep you posted on that – we may ask for a call-in and letter writing campaign in late November/December.
  • All other programs
    • OMH will use the CFR data related to direct care lines and associated expenses to compute the 2% for each provider;
    • They used the state average of 27% for fringe benefits;
    • This process will result in provider specific rate changes;
    • For residential programs – GINS are going out to non NYC providers soon but they will be re-issued in November with the COLA –  NYC will get revised GINS in November as well;
    • Non-Medicaid State Aid Programs – again – they will look at the CFRs;
    • PROS and CLINIC – these have few direct care staff so there will be minimum impact.  The April COLA will have a larger impact on these programs because it will be extended to clinical staff.  Of course, it has to pass the budget process – not a guarantee.
    • We are assuming that NYC funded beds are NOT included, but we are waiting for confirmation.
    • We do not know yet if Reinvestment beds are included.
    • We do not know if Health Home CC under DOH is included and we have asked about the legacy rates for OMH CC: we will let you know when we find out. 

BIP ENHANCEMENTS FOR MEDICAID REIMBURSED RESIDENTIAL PROGRAMS:

  • This is for Medicaid programs only – it is a federal program restricted to Medicaid;
  • There will be more guidance in the next month or so;
  • Emergency regs were recently approved;
  • This program will be retroactive to April, 2014;
  • Applies to any clients taken from STATE PSYCH CENTERS, NURSING HOMES, and STATE CORRECTIONAL FACILITIES  – it is a little different than the SH enhancements below;
  • Providers will receive a 30% increase for those that go directly into a Medicaid reimbursed CR and a 15% increase for those who go directly into TAP;
  • They will use CAIRS data to count the clients from those settings every 6 months (maybe every year) and make the adjustments to your rates;
  • They will continue to count individuals in CRs for 2 years and individuals in TAP for 3 years;
  • They will isolate the BIP payments in their records so that it does not impact your exempt income – they want you to get the entire amount.

 SUPPORTED HOUSING ENHANCEMENTS:

  • You can read the guidance memo here:  https://custom.cvent.com/56C264EFA5214FBC9AEA9BFA37A39907/files/04302279343e41e88c697ba575e2ac33.pdf
  • The money has already started to flow.
  • They are looking at rosters back to January 1, 2014;
  • They have already looked at January to June and have begun sending checks for 106 people.
  • They will look at the CAIRS data for July to November/December for the next round of checks but then they are going to a monthly system so that you get the money sooner;
  • All clients coming from ADULT HOMES, NURSING HOMES, STATE PSYCH CENTERS and STATE CORRECTIONAL FACILITIES meet the criteria.
  • Make sure you are tracking and reporting correctly so that you do not leave money on the table.   

GENERAL ADVOCACY:

  • We have met with OMH, the Counties, DOB and the Governor’s office about next year’s budget over the last few months;
  • We were asked to find out what the backlog might be in CRs and TAP;
  • We surveyed all of you and many responded – thank you;
  • I sent a letter to the Commissioner with copies to OMH senior staff and to DOB staff;
  • It informs them of the backlog – this is critical to their initiatives to get people moved out of State Facilities;
  • I also wrote that we would need $99 million to make us whole from cuts due to inflation and to make sure we have the resources to serve the most challenging coming out of hospitals;
  • You may hear about this because it is a lot of money and many in state government think it is over the top. 
  • I have explained over and over that it is important for them to understand the implications of no COLAs or other increases for many years.  I don’t expect them to give us $99 million in one year but I think it is important for them to know what the number is.  If you talk to any state or county staff that reference this, please repeat this message.  It is, in fact, not over the top.
  • Broken down by housing program type it is:
    • Supported Housing:         $43 million
    • CR-SROs:                            $24 million
    • CR and TAP:                       $19 million
    • SP-SRO:                               $13 million  
  • You can read the letter here:  10-16-14 Sullivan

ANNUAL CONFERENCE:

  • THERE ARE STILL ROOMS AT THE SAGAMORE – they expanded a few years ago by nearly 100 rooms so there is plenty of capacity.

Hope to see you there. 

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