New York State IDD & BH COVID-19 Market Update – View from the Epicenter
In response to the COVID-19 pandemic, intellectual and developmental disability and behavioral health (IDD & BH) providers are addressing historic and unique challenges in a setting that is evolving faster than anyone can keep up with—all while caring for the most vulnerable members of society. The range of funding sources, regulatory requirements and an extensive program continuum, including residential and day services, within the epicenter of the pandemic has created an enormous challenge to providers and is resulting in competing demands.
New York State (State) has, at least for the time being, indicated its desire to sustain the IDD & BH system through this crisis. However, the path ahead to formulate and execute a plan is unclear, creating an unsettled and crisis-driven setting for providers—particularly against the growing likelihood of this crisis continuing for an extended period of time. Although considered essential, IDD & BH providers have also seen their congregate day services ordered closed and are struggling with what the future will bring for some of their programs.
The New York State Education Department ordered all schools closed for a minimum of two weeks and public schools are transitioning to remote learning. But how remote learning translates to special education programs whose services include related service therapies and activities of daily life remains to be seen. And although they have received some assurance about the funding of their center-based programs, the funding of most itinerate services is still up in the air. The State plans on allowing certain itinerant services to be done using telehealth, but the approvals for that are still pending. In addition, the State is somewhat constrained in what it can do since many changes to the services provided and funding received are governed by federal Individuals with Disabilities Education Act (IDEA) laws, which require federal approval.
For IDD services, the State has ordered day services closed and also is moving toward telehealth for certain individual community-based programs and clinic services. Again, although the State has articulated its commitment to maintain the system and is saying it will be offering flexibility to service providers during the crises, many of these changes still require CMS approval through Appendix K waivers and 1135 Waiver Authority. Residential providers are grappling with the difficulty of securing increased staffing during the day to cover for residents who are no longer going to day programs.
These areas are further complicated by a host of operation challenges providers are facing, including little or no protective personal equipment for programs that defy social distancing. In addition, because of shortages in the hospital systems, IDD providers are being told they are not the priority. Residences also are wrestling with how to address residents going home for visits and then returning, along with what to do when a resident or direct support professional tests positive.
The State is looking at how day program staff can be shared with residential programs, although these two services are often not managed by the same agencies, adding complexity to this desirable goal. The State also is trying to secure approval from CMS to ease a myriad of rules, including Medicaid eligibility extensions, face-to-face requirements, Level of Care determinations and site location rules.
We are monitoring the extensive and evolving changes and offer the following recommended best practices with respect to operational and financial strategies.
- Develop an operational plan that includes short-term and long-term changes. In anticipation of the need to similarly redirect staff and serve individuals remotely, providers need to be surveying where the individuals they serve will be located (home/residence) and what their technology capabilities are at those locations (computer and internet).
- Assess what additional staffing will be needed for their residential programs and identify where the might partner with day program providers to access staff.
- Reach out to parents and caregivers to inform them of these changes and obtain authorization to come into their home or to perform such services remotely.
- Establish formal protocols for performing services remotely, including service documentation.
- For the time being, establish a central command team of leaders that can monitor short-term planning, monitor changes to regulation in this fluid environment and be able to pivot quickly if the need arises. This also can be a mechanism to disseminate information quickly to staff, helping reduce redundancy.
- Provide staff education about COVID-19 infection control and develop guidance for staff to monitor individuals who show signs of COVID-19 infection.
- Develop strategies and identify resources to mitigate staff stress.
- Separately track COVID-19 expenses for future reimbursement—read more in this BKD Thoughtware® article
- Develop and employ a COVID-19 CFO to-do list, including:
- Continue timely monthly closes and interim financial reporting
- Step up cash flow analysis, moving to almost daily monitoring
- Reach out to your banks to address their concerns and ensure credit lines will still be available
- Focus on revenue cycle management, including billing and receivables
- Analyze the impact of any funding changes (increases or decreases) and match it against increases or reductions in expenditure levels
- Identify where there may be opportunities to obtain grants to cover increased expenditures
- Hold regular calls with line managers (billing, payroll, AP, etc.) during these times when most employees are working remotely
As with most topics related to COVID-19, changes are being made rapidly. Please note that this information is current as of the date of publication.
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