Sept. 28th Deadline! Fiscal Intermediary Rule Changes
Sept. 28th Deadline! Financial Intermediary Rule Changes
Urgent Deadline Approaching! FI Rule Changes!
We are truly disheartened by the release of 2019 ADM-07R Draft Service Documentation for Fiscal Intermediary (FI) Services. This was the 4th major proposed policy change (ADM) issued by OPWDD in the month of August. OPWDD has already had over 2 years to address deficiencies in this policy after initially withdrawing it in the Spring 2024 following overwhelming negative public comment.
OPWDD has not provided anywhere near adequate time for our community study, review, and comment on 61 pages of text in 4 ADMs and a 17 page form! Especially when all of these high-stakes proposals 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 understand, analyze, and comment on this proposal.
Together We Can Fight Back
Public Comment on This Rule Change is Ending Monday Sept 28th. You must act now! Our Community needs more time to provide meaningful feedback to this high stakes proposl.
Please take just a minutes or two to send an email to rau.unit@opwdd.ny.gov. You need to write “ADM #2019-07R FI Service Documentation” in the subject line so OPWDD knows you’re writing about this issue. And please, we’d love you to CC: us on your email at info@c4sd.org to show our solidarity and to help organize our voice!
Share your comments and your lived experience, and while you’re at it, we’d love you to include these suggestions for a more effective and individualized approach:
Ask OPWDD To - Extend the comment period for ADM 2019-07R by 30 days, to October 28th.
Ask OPWDD To - Provide more time for public comment by giving more time between draft policy (ADM) release dates. OPWDD’s record of guidance documents shows it has never posted more than nine ADMs in a single year. One release per month is a reasonable pace. Four releases in a single month is not.
We’ll be hosting Town Hall discussions on Wednesday, September 16th at noon and -7:00 PM to continue to rally support around this critical issue.