NYS Council Recommendations for OASAS

August 28, 2025

Just sent this to OASAS.  THANK YOU to all who contributed to this effort!  
———- Forwarded message ———
From: Lauri Cole <lauri@nyscouncil.org>
Date: Thu, Aug 28, 2025 at 11:34 AM
Subject: NYS Council Recommendations

Good morning,

Thank you for the opportunity to share our feedback as you consider ways to mitigate the negative impacts of HR1 on the OASAS system of care, and as you consider regulatory and other changes that would streamline required OASAS provider tasks and activities that will allow our staff to devote more time to the provision of high quality care to the individuals we serve.

We approached this exercise with the assumption that (given the current environment) the recommendations that would be most beneficial to you at this juncture are those that do not require additional resources from the OASAS agency budget, or the state’s general fund; however, we are also aware that OASAS staff time is a major part of this equation.  We acknowledge that many of the recommendations (below) would require focused attention by valued OASAS staff.  As such, we urge the Office to convene and call upon providers, individuals in care, peers, family members and other stakeholders to come together to consider solutions to the issues listed below).  

We would be happy to speak with you about any of our recommendations at your convenience.  Thanks again for this opportunity to share our thoughts and ideas:

NYS Council recommendations:

  • Carve out OASAS (and OMH) outpatient programs from the state’s Medicaid managed care program.  Doing so would save (at a minimum) $400M/year.  (Note:  MCOs are currently able to keep a total of 11% of the funds received from the state for profit and administrative overhead.)  The vast majority of these vendors are for-profit entities with one goal in mind – to make money for the company and its shareholders.  Furthermore, New York State does not robustly enforce the laws, regulations and guidance MCOs are required to (but often do not) follow.  There is no value add to employing these third parties and NYS can ill afford to pay expensive middlemen for services that result in increased barriers to access to and continuity of care.  
  • OASAS financial audits should occur on a 5 year interval rather than the current 3 year interval.  Historically, financial audits occurred on a five year cycle and if providers are doing well and operating ‘in good standing’ the interval should be extended thereby saving scarce resources and providing relief to overburdened providers.  
  • Simplify the OASAS Incident Reporting and Incident Oversight processes.  At the present time, both are a significant administrative strugglesand both are resource intensive. 
  • Issue a blanket waiver allowing OASAS providers to keep excess state aid funds and allow these funds to be applied in other areas of programming, without restrictions.
  • Simplify what is currently a very cumbersome OASAS budget submission process.
  • Fingerprinting systems that don’t talk to one another (OMH,, OASAS, DoH) create delays in hiring and barriers to staff being able to work in other programs in the same agency without having to go through the process over and again. In this regard, there should be reciprocity in information sharing that can result in some badly needed workforce shortage relief. 
  • OASAS 820 programs are required to complete treatment plan and treatment plan reviews monthly resulting in frequent need for review and sign offs.  As we understand it, other OASAS programs have the ability to complete this process via notes rather than their having to formally update the treatment plan.  OASAS should flex this 820 requirement to bring it in line with other OASAS requirements for programs such as the OASAS Article 32 – Part 822 (outpatient clinic).
  • Conflicting OMH and OASAS regulations/positions on various topics (physical space requirements, use of cameras, regulations, policies, etc.) are often barriers to the implementation of integrated care. A workgroup pf providers, care recipients and other stakeholders should be convened to provide solutions to the current barriers that result in fragmented care. 
  • CASAC licensees are required to undergo a background check every time they seek to renew their credential. We think this perpetuates stigma and it is also is inefficient.  OASAS should remove this requirement.
  • Permit MHOTRS clinics to operate beyond the hours indicated on the operating certificate and by appointment without requiring a practitioner be present in the clinic, even when the visit employs the telehealth modality.
  • Make permanent all COVID era telehealth flexibilities and make the current policy that requires insurers to pay the face to face rate for telehealth services until 2027, permanent.  
  • Allow services to be delivered and billed in time frames that best support client needs, preferences and positive outcomes rather than adhering to arbitrary time frames driven by billing requirements that are neither person centered or based on best practices.