August 21, 2025

Earlier today I received an email from OASAS leads requesting that we send them our recommendations for how to mitigate the likely negative impacts associated with implementation of provisions of the so-called Big Beautiful bill (HR1).  I am interpreting the request to be the same as the OMH request that focuses our attention on only those areas where OASAS can make a change without requiring other state agencies or regulators to get involved and agree, and without a significant price tag in order to implement the recommendation.  

Anticipating a request from OASAS, I have been putting together a list of our recommendations The draft recommendations based on NYS Council member agency feedback and input from recent workgroups and other meetings as well as the exchanges I have with our members every day where members often make a suggestion or recommendation that could provide some relief while also offering some protection from future harm.  

Please review the DRAFT list (below) and feel free to send me your additions.  Also feel free to correct me where I may be off base, and more generally, review the list for completeness.   THANK YOU!!  

My goal is to send our recommendations to OASAS by Wednesday, August 27 at COB if not sooner.

Here’s what I have so far:

• OASAS 820 programs are still required to complete treatment plan and treatment plan reviews monthly resulting in very frequent need for review and sign off. Other OASAS programs are apparently able to do this through 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).
• OASAS audits should occur every five years instead of every three.  Historically, financial audits occurred on a five year cycle.   If providers are doing well and operating ‘in good standing’ the interval should be extended, 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 struggles and are very resource intensive. 
• Issue a blanket waiver allowing OASAS providers to keep excess state aid funds and allow these funds to be applied (by the provider) without restrictions.
• Simplify what is currently a very cumbersome OASAS budget 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 again.  There should be reciprocity in information sharing that will deliver some badly needed workforce shortage relief. 
• Conflicting OMH and OASAS regulations/positions on various topics (physical space, cameras, regulations, policies, etc.) are barriers to the implementation of integrated care and a workgroup pf providers should be convened to provide solutions to the current barriers that result in bifurcated care. 
• CASAC licensees are required to undergo a background check every time they seek to renew their credential. We think this perpetuates stigma and is deeply 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.