August 8, 2025

Next week I will be meeting with OMH leads and other association reps. to discuss our recommendations for how the Office can mitigate the impacts of HR 1 – the so-called Big Beautiful bill, preserve provider viability, sustain access to care, etc.

Below is a part of the communication I received from OMH today urging a meeting of advocates next week to provide some limited recommendations in advance of coming budget conversations.   As you will read, at this juncture OMH is limiting our recommendations to only those areas where OMH has sole oversight and discretion. So that means our recommendations can’t include changes where the regulation or requirement in question originates at the federal level, nor can we include scope of practice changes that would require SED agreement (Remember:  SED oversees practitioner scope of practice whereas OMH has oversight of regulations for its licensed, certified or otherwise regulated Programs and Services), or areas where OASAS has shared oversight responsibility.  I know this is frustrating but we will turn this around in future advocacy meetings).

The parameters OMH has put on this particulate exercise are significant, however, we will make sure our full list of recommendations for regulatory relief, efficiencies, etc. makes it to all of the people and all of the desks where it needs to go at the state agencies, downtown, etc.

(excerpt from OMH email)

OMH leadership would like to meet with you next week for a time-sensitive request for recommendations. We are requesting actionable recommendations from you (i.e., your top 3) that would alleviate pressure on provider organizations in the mental health system and support the individuals impacted, including specifically how and why your recommendation would help. We’re seeking suggestions that OMH can administer itself as a state agency as opposed to recommendations OMH would need regulatory partnership with other state agencies to implement.  The way we’ve been thinking about it here at OMH is that recommendations to mitigate risk and plan for impact might fit in three overarching domains: 1) Fiscal mitigation and revenue maximization; 2) Regulatory relief; and 3) Programmatic and system design/redesign.

As NYS Council members know, our Association has been hard at work identifying our budget and policy priorities for the coming legislative session.  I’m hoping you can take some time with your key staff early next week to gather your suggestions (along with citations to the actual OMH regulation, guidance, requirement, etc.) for the Office to consider.  I would be grateful for your recommendations no later than Wednesday COB.  I know the timeline isn’t great but (once again) this is short notice from the Office.

THANK YOU!