December 16, 2020
According to information I received on a call with Trisha Schell Guy, Steven Schrager and Vittoria Parry at OASAS, OASAS will post on its’ website (see below – in the section re: CFRs) instructions for its’ funded providers that modifies the usual CFR reconciliation process. While providers are still required to file their CFR within 5 months after the end of the fiscal year, and OASAS intends to review and reconcile it internally, OASAS will not take steps to take back any surplus funds based on the CFR. Instead, OASAS will share the results of the CFR close out with the provider but it will not reconcile and take back until the end of your 2021 fiscal year. In essence, OASAS is merging the two year reconciliation process in hopes of assisting providers to maintain financial stability. All other rules of the road apply as it relates to CFR reporting and filing.
Tto clarify any possible misinterpretations, OASAS has indicated their intent is not to simply delay the payback of any 2020 surplus, but to allow providers to offset any 2020 surpluses with 2021 losses, and vice versa. It will be a two year reconciliation, so while providers will still file annual CFRs, they will be reconciled together.
Revised OASAS year-end reconciliation procedures for calendar years 2020 and 2021 and fiscal years 2019-2020 and 2020-2021 have been posted for all funded providers. Details may be found on the OASAS website at oasas.ny.gov/providers/year-end-funding-reconciliation.
We have yet to hear from OMH on this issue. Stand by for more.