It is impossible to interpret this behavior pattern as a sincere attempt by OPWDD to engage with the public.
POSITION STATEMENT - #2019 ADM-07R Draft
Service Documentation for Fiscal Intermediary (FI) Services
To support the ability of the community to respond adequately,
the comment period for this ADM must be extended 30 days to October 28th.
The Coalition for Self-Direction (C4SD) provides these comments on behalf of the community of family advocates in New York State. We are a grass-roots organization of parent-volunteers who seek to promote and preserve freedom of choice for all people with developmental disabilities.
This ADM, 2019 ADM-07R Draft, was the fourth one issued by OPWDD in the month of August. Prior to that release, OPWDD took many months to internally review and hone the ADMS. This specific one on Fiscal Intermediaries was the rework of an ADM that had been silently withdrawn in Spring of 2024, following negative public comments, which means that OPWDD had been working on it for over two years. The release schedule chosen by OPWDD gave the advocacy community only a short time in which to study 61 pages of text in five documents: 4 ADMs plus a 17-page form. Each of the five docs has a reading-ease score of either 'Difficult to read' or 'Very difficult to read'.
It is impossible to interpret this behavior pattern as a sincere attempt by OPWDD to engage with the public. We simply do not have the time to adequately study this ADM, which OPWDD has been working on since April 2024. We call upon OPWDD to take corrective actions:
1.Extend by 30 days the comment period for ADM 2019-07R, to October 28th.
2.In the future, space out the release of ADMs. It is a rare year in which OPWDD releases morethan 6 ADMs. Releasing one ADM per month would be a reasonable pace. Four in a single monthwas not reasonable.
Sincerely,
Jim Karpe
Father of two adults with I/DD
OBO The Board of The Coalition for Self-Direction
Heather Burroughs, Stacey Cagan, Jackie Ceonzo, Jim Karpe, Susana Montes, Chris Palega, Molly Sebastian