The Office for People With Developmental Disabilities (OPWDD) and the New York State Department of Health (DOH) held a call with Provider Association representatives to announce a change in both the retainer rate program and the enhanced IRA rate initiative. These changes will provide critical sources of cash flow and reimbursement that would otherwise have been delayed indefinitely given the State's cash management actions affecting approval of all new rates.
OPWDD and DOH will schedule a webinar for this Thursday to review the changes with providers. The required attestation will reportedly be available by that time. Please be sure to look for the invitation to Thursday's webinar, and be sure someone from your agency attends.
Retainer units described below will be authorized as of April 16, except for retainer units authorized for Community Habilitation (CH), which will be retroactive to March 18.
Enhanced IRA Rate Alternative
: Instead of adding additional Direct Support Professional (DSP) hours and associated costs to IRA rates for individuals who attend another agency's Day Habilitation (DH) or Prevocational (PV) program, DOH will authorize an equivalent number of CH-R 15-minute units, which must be billed at the group rate of approximately $6.50 per unit. Since CH-R is a fee, the amount will be different than your agency's cost per hour of direct care (higher or lower).
Retainer Payment Alternative
: Instead of combining revenue for DH, PV and CH for the 6-month period, dividing by 6 and multiplying by .8 in order to calculate a monthly retainer rate, OPWDD and DOH will take the 6-month average of units delivered for each program divided by 6 and multiplied by .8, so as to authorize allowed monthly retainer units that will be billed using your current rate for each program.
Services actually delivered and documented pursuant to the applicable regulations and ADM may still be billed in order to make up the 20%. DH may still be delivered in IRAs and billed for individuals for whom you are not billing for CH-R, except you will not be able to also bill a retainer day for such individual.
Unfortunately, under this new approach there is no way to capture respite revenue in the calculation of the retainer amount.
There will still be a monthly reconciliation. Combined revenue in excess of 100% will be subject to recoupment.
This is a creative and very helpful alternative to the previous proposals that were delayed, but we will have to study it and learn the nuances before proceeding.