FAQs
The following provider questions and OASAS answers are from the Restructure Addiction Services Financing Project Town Hall Community Forums held on May 23, 2024, and November 1, 2023. Please note that these FAQs are cumulative, and the most recent FAQs are displayed first.
May 23, 2024 - Questions & Answers
Q1. Is the first project taken on by RASFP to be developing an alternative to net-deficit financing?
A1. Yes, that is the definition and intent of the project in its entirety. The RASFP project focuses on a thoughtful and comprehensive approach to developing an alternate funding mechanism to net deficit funding on a program-specific level.
Q2. Did multiple people from the same organization respond to the surveys? Additionally, is it restricted to one response from each organization?
A2. Survey participation was restricted to one person per organization.
Q3. As an LGU, we responded to the survey for our LGU admin program. However, LGUs are also in a position to need to conform to whichever funding model is eventually chosen for PRUs where funds are passed through our SAFAs. Will there be any specific outreach to LGUs during the RASFP process?
A3. Yes, OASAS values the LGUs' knowledge and expertise. LGUs will be solicited for feedback at various points throughout the RASFP process, including inclusion in the various cycle focus groups.
Q4. Is OASAS taking the impact of COVID into consideration when reviewing the data for 2020 and 2021?
A4. Yes, we are taking the impact of COVID-19 into consideration when reviewing the 2020 and 2021 data.
Q5. I think under-compensated care should be the term that is used. Even if we are billing and are efficient, the cost of providing good care requires few positions i.e., MAT and Psych NP’s that do not cover their own cost at current rates.
A5. During our evaluation, OASAS is reviewing undercompensated care pools and underinsured clients to assess how to address the funding needs of these specific groups.
Q6. Is there a way to volunteer for the Cycle 1B focus group?
A6. OASAS has been very thoughtful and purposeful when selecting providers to participate in the focus groups to ensure the whole NYS continuum is represented and reflects a diverse mix of NYS providers, e.g., providers from different programs, service types, and sizes, those funded largely by Medicaid or state aid, etc.
Q7. Are you giving any considerations or weights to programs running integrated services compared to traditional SUD services?
A7. OASAS is looking broadly at different frameworks of how funding is currently being provided and the programs that serve the citizens of New York. We will be better suited to address this consideration as we assess the alternate funding mechanisms available, evaluate provider feedback received, and conduct funding models to test our findings.
Q8. Seems to me that for the new models being considered to be effective, cost of care and reimbursement rates would be important factors. Anything you can share on the work being done in those areas to date?
A8. We interpret this question to be regarding Medicaid rates. Over the last year, OASAS has invested $70 million into Medicaid rate enhancements for SUD services. Part of the RASFP effort will compare New York SUD Medicaid rates nationally.
Q9. Can the current indigent care pool currently available to public hospital systems be made available to OASAS programs to fund care to the uninsured or underinsured?
A9. No. The indigent care pool currently available to the public hospital systems cannot be made available to OASAS providers that are not hospitals.
Q10. Is it still on the table for discussion about Private Insurance to start paying FFS rates or is it official?
A10. It's official. Commercial insurance companies must pay the Medicaid rates starting January 1, 2025.
Q11. I echo the reimbursement concern and I ask that not only that be considered but holding the payors accountable for paying those rates is a huge issue.
A11. OASAS shares these concerns.
Q12. Can OASAS provide billing guidance to providers as we move forward? So that providers can bill to their best ability and maximize potential revenue.
A12. Yes. OASAS currently provides billing guidance to providers and will continue to find opportunities to do so to assist providers in maximizing their revenue potential. For general billing questions, please submit them via email to [email protected].
Q13. Do you have a projected timeline for cycles 2 and 3?
A13. Cycles 2 and 3 will follow a similar trajectory as cycle 1. OASAS is projecting to begin its research for cycles 2 and 3 in the fall of 2024. After an internal OASAS assessment of the data collected, provider engagement, including additional surveys and focus groups, these cycles may commence in 2025.
Q14. Not only parity in terms of payments but are covered by the Commercial plans.
A14. Yes, OASAS concurs with this sentiment.
Q15. Technical assistance to maximize billing would be great, especially for billing for items that are not explicitly listed in the APG manual, discussing variations between Medicare/Medicaid and what rules to follow, etc., as it always leads to confusion.
A15. OASAS appreciates this perspective.
Q16. Would commercial insurance have to also pay for residential, as does Medicaid?
A16. No, it only applies to outpatient services.
Q17. Is there any protection built in to protect third-party revenue generated that isn’t deducted from OASAS funding?
A17. OASAS continues to evaluate third-party revenue and its role in future RASFP funding models. We are examining the best means to equitably distribute funding while opening funding to all not-for-profit certified providers and incentivizing quality care. From that perspective, we don’t have all the answers today, but we intend to find a model to meet these objectives.
Q18. Did I understand you to say that other states have phased out NDF in favor of more modern processes or you are thinking that maybe we are behind in our methods? Is it possible that we are ahead of other states with NDF?
A18. We cannot validate whether the other states we spoke to ever had net deficit funding models or not. OASAS did not conduct a historical funding view or inquire how other states developed their current funding methodologies. However, we did not find any states that currently provide their state aid or federal SUPTRS block grants through a net deficit financing mechanism. The landscape of SUD services has changed and will continue to do so. In response, we believe to best serve those challenged by substance use and addiction, the way we finance these services must evolve as well.
Q19. Does working under a framework that all not-for-profit licensed OASAS providers will receive some form of state aid, without a firm expansion of total state aid, run the risk of diluting state aid grants in such a way that all providers receive insufficient aid for un/uncompensated services that are provided?
A19. OASAS continues to examine data, develop funding models, and focus on how to equitably distribute funding to provide aid more efficiently for SUD services. We’re working through these same questions and will seek provider feedback and input throughout this process to assist with finding the best answers to these issues.
Q20. I think that some of the input will look different when you get to the services that aren’t reimbursable by insurance, things like the prevention and recovery fields.
A20. OASAS agrees and appreciates this perspective.
November 1, 2023 - Questions & Answers
Q1. What are the differences in the cycles?
A1. While the elements for each cycle will be essentially the same, the service programs included in each cycle will be different.
Q2. Will slides be made available?
A2. The Town Hall is recorded and posted to the OASAS RASFP webpage. The recorded presentation, which includes the slides, is available on the main RASFP webpage.
See also Q37
Q3. Within organizations, who will be receiving the surveys?
A3. The survey will be sent to the Chief Executive Officer and Financial Officer listed in the Provider Director System. Please make sure the information for your agency is current. Instructions for changing contact information are available at https://apps.oasas.ny.gov under the Application Documentation heading. For assistance or questions regarding the PDS, please contact the OASAS Data Management Unit at [email protected].
See also Q19
Q4. Will stakeholders include DOH, OMH, Plans?
A4. While we may seek input from other State agencies, they will not be part of the stakeholder groups. This project is specifically about the State aid provided by OASAS, not funding from other agencies, insurance plans, or Medicaid.
Q5. I'm not clear on the differences between the phases of implementation. Are you saying that the three cycles will apply to different parts of the treatment delivery system? Have you all decided on which parts of the system you will start with?
A5. Each cycle will focus on different parts of the funded OASAS system. The entire funded OASAS system will be included. Cycle 1 will focus on a group of services that have interrelationships (i.e., funding mechanisms, revenue opportunities, etc.), and this group of services will be worked on until the cycle process moves to implementation, and then cycle 2 will begin with a review of another group of services and the same for cycle 3. We have approximated how long a cycle will take but, if necessary, the timeline will be adjusted to ensure all tasks can be completed.
See also Q10, Q12
Q6. Will the process of moving from Net Deficit Financing (NDF) have an effect on vulnerable populations (i.e., undocumented, un and underinsured, those with historically problematic access to care? These folks do seem most to benefit from NDF.
A6. The primary goal of this project is to ensure more equitable and sustainable care delivery to all New Yorkers.
Q7. Will providers with pending applications in NYSE-CON receive a survey?
A7. All providers designated as operational in the OASAS Provider Directory System (PDS) will receive a survey.
Q8. Will for-profit operators have opportunities to apply for funding?
A8. No, under Mental Hygiene Law, OASAS cannot fund for-profit agencies.
Q9. Will there be a 'held harmless" provision so no agency will be harmed with a loss of funding?
A9. The process for implementing a new funding method will consider the funding impact on providers as part of that process.
Q10. Are these cycles to be applied to each OASAS funded service type?
A10. Each cycle will focus on different parts of the funded OASAS system. The entire funded OASAS system will be included. Cycle 1 will focus on a group of services that have interrelationships (i.e., funding mechanisms, revenue opportunities, etc.), and this group of services will be worked on until the cycle process moves to implementation, and then cycle 2 will begin with a review of another group of services and the same for cycle 3. We have approximated how long a cycle will take but, if necessary, the timeline will be adjusted to ensure all tasks can be completed.
See also Q5, Q12
Q11. Does this mean there will be a 5-year delay in making progress/change toward integrated care (SUD/MH/Primary care)?
A11. No. There are separate discussions that are ongoing now to address the intersection between substance use, mental health, and physical health. These discussions are guiding current improvements to address co-occurring conditions.
See also Q15
Q12. So, there are different services are in each cycle? For example, cycle 1 is treatment?
A12. Each cycle will focus on different parts of the funded OASAS system. The entire funded OASAS system will be included. Cycle 1 will focus on a group of services that have interrelationships (i.e., funding mechanisms, revenue opportunities, etc.), and this group of services will be worked on until the cycle process moves to implementation, and then cycle 2 will begin with a review of another group of services and the same for cycle 3. We have approximated how long a cycle will take but, if necessary, the timeline will be adjusted to ensure all tasks can be completed.
See also Q5, Q10
Q13. Is this project just for NDF or all the financing of around SUD services?
A13. This project is specifically about how State aid is provided by OASAS to support addiction services, and not necessarily about the funding from other agencies, insurance plans, or Medicaid. However, all financing utilized to support addiction services will be reviewed. The goal of the project is to develop a better funding approach to provide more equitable and sustainable care delivery, and the resulting funding methodology and implementation across the field is not yet determined.
See also Q34 and Q43
Q14. Looking at utilization from claims will be critical, but we hope that there will be a methodology developed to capture, assess and prioritize unbillable services.
A14. Third Horizon Strategies will be looking at several factors as they work to develop alternative funding methodology proposals.
Q15. How does this project interface with the integrated care project (single licensure, etc.)
A15. There are separate discussions that are ongoing now to address the intersection between substance use, mental health, and physical health. These discussions are guiding current improvements to address co-occurring conditions.
See also Q11
Q16. Do you anticipate a different reporting mechanism other than CFR?
A16. At this time, it is expected that providers will continue to submit annual CFRs in addition to any other required OASAS service reporting.
Q17. Can you share a bit more outside of surveys what role do you anticipate providers having in this process?
A17. The consultant, Third Horizon Strategies (THS), will convene stakeholder/focus groups to collect information related to each type of service. These groups will be made up of a cross-section of providers to ensure a representation of the funded OASAS system, including large and small programs, upstate and downstate programs, urban/suburban/rural programs, etc. THS will also interview various providers and programs for additional information as necessary.
See also Q31
Q18. Why will it take five years to assess the needed changes?
A18. The OASAS-funded system is large and complex. It would not be practical or even possible to change the funding mechanism for the entire system at once. By proceeding in phases, the needs of each segment of the system can be addressed. This would also allow for evaluation of the process at various points which would help inform changes in the process as it continues.
Q19. Is there one survey response per agency?
A19. The expectation is for one survey response per agency. The survey will be sent to the Chief Executive Officer and Financial Officer listed in the Provider Director System. Please make sure the information for your agency is current. Instructions for changing contact information are available at https://apps.oasas.ny.gov under the Application Documentation heading. For assistance or questions regarding the PDS, please contact the OASAS Data Management Unit at [email protected].
See also Q3
Q20. What about Board of Directors?
A20. We have brought up the issue of having Board of Directors respond to the survey with THS. However, because the survey is directed at fiscal information, we have determined that the survey will not be sent to providers’ Board of Directors.
Q21. What connection will there be between financial performance and outcome/clinical performance?
A21. Third Horizon Strategies will be looking at several factors as they work to develop alternative funding methodology proposals. The purpose of this project is to determine if there is a better funding methodology that would encourage performance and efficiency but still provide stable funding that enables providers to continue to provide addiction services.
See also Q38, Q41
Q22. A number of undocumented clients are being referred to our residential treatment program. Several referred clients have CC’d OASAS on the email with hopes of an expedited acceptance. There is a shelter fee which needs to be covered by HRA along with payments for medical, psychiatric, and counseling services (Billed to Medicaid) while in the program. Is the provider mandated to accept them because we are deficit funded?
A22. OASAS-funded providers cannot refuse appropriate treatment to a patient due to an inability to pay for treatment services, must ensure that any individual who requests and is in need of treatment for injection drug use receives such treatment, and that each pregnant individual who seeks or is referred for, and would benefit from, treatment services receives preference in admission to treatment.
See also Q39
Q23. When you say more equitable - assuming licensed programs that don't get funding would be considered in the future?
A23. The goal of the project is to develop a better funding approach to provide more equitable and sustainable care delivery, and the resulting funding methodology and implementation across the field is not yet determined.
Q24. Is the new Restructuring Funding Project webpage live, and if so where is it located on the OASAS website.
A24. Yes, the webpage about this project is live and can be found at the main RASFP webpage.
Q25. So, when will these changes directly impact budgets? 2024? 2025? so that we can anticipate future funding changes.
A25. We do not have a date yet on when these changes will impact the development of provider budgets. As the project proceeds forward, information on this and other important information will be made available through community forums and status updates posted to the main RASFP webpage.
See also Q32 and Q42
Q26. Currently the reimbursement methodology is NDF = Total operating expense less total revenue? What does it mean to move away from NDF?
A26. The purpose of this project is to determine if there is a better funding methodology that would provide equitable and stable funding that encourages performance, efficiency, and improved care delivery.
Q27. Can treating unfunded to treated as an expense on the budget?
A27. We believe the question is asking if there is a possibility for the expenses related to treating uninsured patients to be considered in the new approach to be developed. The purpose of this project is to determine if there are better funding methodologies to provide equitable, stable funding that encourages performance, efficiency, and improved delivery of addiction services.
See also Q26
Q28. How do you see LGUs contributing, supporting OASAS in this process, if at all?
A28. The LGU is an important part of the funding system and input from the LGUs will be taken into consideration.
Q29. It looks like the implementation of cycle 1 is scheduled for June 2024. That is about 8 months away. Have you decided which portion of the system you will start with? Was there a starting place with Third Horizon in terms of your desired outcomes and priorities?
A29. We did not enter into the project with any predetermined outcomes. Third Horizon Strategies (THS) is tasked with determining alternative methods of payment and making recommendations based on their experience and research. Interaction with providers will provide valuable information in developing those recommendations. Cycle 1 will focus on a group of services that have interrelationships (i.e., funding mechanisms, revenue opportunities, etc.), and this group of services will be worked on until the cycle process moves to implementation, and then cycle 2 will begin with a review of another group of services. We have approximated how long a cycle will take but, if necessary, the timeline will be adjusted to ensure all tasks can be completed.
See also Q5, Q10 and Q12
Q30. Instead of deficit funding, why not simply elevate the APG rates which would benefit all providers???
A30. APG rates only apply to billable outpatient programs and do not address the needs of all funded programs in the OASAS system.
Q31. How is Third Horizon getting input from providers who have doing this work on the ground for decades and best understand local communities?
A31. The consultant, THS, will convene stakeholder/focus groups to collect information related to each type of service. These groups will be made up of a cross-section of providers to ensure a representation of the funded OASAS system, including large and small programs, upstate and downstate programs, urban/suburban/rural programs, etc. THS will also interview various providers and programs for additional information as necessary.
See also Q17
Q32. Will there be any financial coaching, consultation provided? As some agencies are not as financially educated as others.
A32. Yes, training on the selected new funding system will be provided.
Q33. When will these changes directly affect our budgets/funding? 2024? 2025? 2026?
A33. We do not have a date yet on when these changes will impact the development of provider budgets. As the project proceeds forward, information on this and other important information will be made available on the main RASFP webpage.
See also Q25 and Q42
Q34. Will discussions include the immense expense we incur to simply get plans to reimburse for provided services? Tremendous financial losses there.
A34. This project is specifically about the State aid provided by OASAS, not funding from other agencies or Medicaid. Please contact [email protected] about issues with managed care plans not paying in a timely manner.
See also Q13 and Q43
Q35. Will this project continue if the administration changes in 5 years?
A35. The goal of restructuring net deficit financing has been in development for many years and across multiple administrations. While there’s no way to accurately predict the future, it is our expectation that this project will be supported through to implementation.
Q36. As a CCBHC demo, will the survey address integrated providers?
A36. All OASAS-funded programs are expected to be included in the survey.
Q37. Will you be sending out the slides and/or the recorded webinar, or maybe links to both?
A37. The Town Hall is recorded and posted to the OASAS RASFP webpage. The recorded presentation, which includes the slides, are available on the main RASFP webpage.
See also Q2
Q38. So, the reimbursement/funding that is in play is net deficit funds (@$500m) however, we will look at how it might be used differently to support stated outcomes. Is this correct?
A38. The primary goal of this project is to ensure more equitable and sustainable care delivery to all New Yorkers. Third Horizon Strategies will be looking at a number of factors as they work to develop alternative funding methodology proposals. The purpose of this project is to determine if there are better funding methodologies to provide equitable, stable funding that encourages performance, efficiency, and improved addiction service delivery.
See also Q21, Q41
Q39. Follow up on the undocumented question. Does that mean we don't accept them under the current structure?
A39. OASAS-funded providers cannot refuse appropriate treatment to a patient due to an inability to pay for treatment services, must ensure that any individual who requests and is in need of treatment for injection drug use receives such treatment, and that each pregnant individual who seeks or is referred for, and would benefit from, treatment services receives preference in admission to treatment.
See also Q22
Q40. Does OASAS have any priorities for the program types designated for cycle 1?
A40. It is anticipated that the first cycle will focus on treatment programs.
Q41. Will funding be based on outcome/performance based?
A41. Third Horizon Strategies will be looking at several factors as they work to develop alternative funding methodology proposals. The purpose of this project is to determine if there is a better funding methodology to provide equitable, stable funding that encourages performance, efficiency, and improved delivery of addiction services.
See also Q21, Q38
Q42. How is OASAS preparing the 2024 budget if there might be changes as early as June 2024?
A42. We do not have a date yet on when these changes will impact the development of provider budgets. As the project proceeds forward, information on this and other important information will be made available on the main RASFP webpage.
See also Q25 and Q32
Q43. Will this approach take a look at how we bill for services and the technical assistance that is needed by many programs? We can restructure how we fund but if providers struggle with billing and payors deny- we need help in this area.
A43. This project is specifically about the State aid provided by OASAS, not funding from other agencies or Medicaid. Please ontact [email protected] about issues with managed care plans not paying in a timely manner.
See also Q13 and Q34
Q44. Net Deficit funding is very important for CBOs who receive it to provide services that they may not otherwise be able to provide.
A44. We understand the significant role that OASAS funding plays in the provision of services delivered by community-based organizations and other government units. The primary goal of this project is to ensure more equitable and sustainable care delivery to all New Yorkers.