(Oct. 8, 2024) The State Department of Health sent a communication to Adult Day Health Care programs that have received American Rescue Plan Act funding. Programs have been waiting for reporting forms and spending guidance clarifications from the Department.   

According to initial guidance, the first quarterly spending reports were due Oct. 15th. DOH now states that reporting surveys will be released to programs the week of Oct. 7, 2024 and should be completed and returned to the department no later than Oct. 21, 2024. 

Programs can reach out to the Department at ADHC_ARPA@health.ny.gov with questions regarding reporting and the FAQ.  You may also email me with questions or concerns.  

 Please find the DOH communication to ADHC programs below: ​​​​​​​

Supplemental American Rescue Plan Act (ARPA) Funding Guidance: Adult Day Health Care (ADHC) Programs and AIDS Adult Day Health Centers (AADHC) 

The following are reinforced guidance from the Department’s Initial and Subsequent ARPA Funding Guidance and additional FAQs for ADHCs and AADHCs (collectively referred to as ADHCs hereafter) 

1. The Department identified three categories of expense on which eligible program sites can choose to spend their awards. These include: 

a. Workforce: Workforce retention strategies, recruitment, and retention of a racially and ethnically diverse and culturally competent workforce and development, implementation and promotion of trainings for staff. 

b. Service Support: Supplement community integration activities. Includes supplementing the cost of member transportation to and from the program and to activities that expand community integration. 

c. Emergency Preparedness: Building appropriate personal protective equipment (PPE) stockpiles from state-authorized sources for ensuring that staff can deliver care in a safe and effective manner during public health emergencies.  

2. Program sites may use their awards to fund recruitment, retention, and training for nurses and staff who directly provide or supervise the provision of services. Funding cannot be used to pay current wage levels, including overtime, for any employees or salary increases for administrative staff, managers, and executive staff. 

a. Funding cannot be used to supplant current or already planned expenses. For example, a site cannot use this funding to cover existing trainings or monthly payments on technology purchased prior to the receipt of the award. 

b. Eligible program sites may begin spending their awards once received. Any expenses incurred prior to this date are not eligible for funding. 

3. Eligible program sites must use their awards to develop and implement the programs and strategies outlined in their spending narratives submitted to the Department as part of the attestation and survey.  

4. Eligible program sites may adjust their spending plans and budgets by resubmitting a new ARPA ADHC Spending Plan to the Department. Subsequent guidance indicated that programs could redistribute the amount or timing of funds to accommodate additional funding once final awards were made without prior approval, as long as the approved spending categories did not change. If your program site must submit an adjusted spending plan, it may be sent to: ADHC_ARPA@health.ny.gov.  Any adjustments must comply with the spending guidelines in this document. 

5. Funds must be expended by July 31, 2025. All sites must report their activities and submit requested documentation quarterly beginning October 15, 2024. The first report will cover the period from receipt of award to September 30, 2024. Surveys will be released to programs the week of October 7, 2024 and should be completed and returned no later than October 21, 2024. Previous guidance indicated that training materials would have to be approved by the Department, however, subsequent guidance indicated that training materials may be submitted with quarterly reports. 

The goal of providing these funds is to ensure that those ADHC programs that are open and operating are well staffed with highly qualified and well trained aides, nurses, home care providers and support staff to provide needed health care, support with ADLs and IADLs, and person-centered activities and community integration opportunities in compliance with the HCBS Final Rule. 

FAQs 

Workforce 

Q: My administrators serve multiple roles at the Center, including direct care. Why are they not eligible for workforce enhancements like retention or end of year bonuses? 

A: The goal of this funding is to ensure an adequate, well trained, culturally competent workforce to support sustainability and expansion of ADHC programs across the state. In no case can these grant funds be used to pay salaries or overtime, but if your administrative staff spends at least 80% of their time in direct care roles with registrants (including providing nursing, OT, PT, Speech/Language therapy; driving registrants to or from the Center or activities; supporting ADL or IADL needs or supervising any of these activities), they may receive enhanced benefits including bonuses and participate in training to enhance their direct care skills. 

Q: Can I include my maintenance staff and drivers in the direct care workforce for purposes of this grant? 

A: Yes, as long as the staff works exclusively for the Center or devotes at least 80% of their time supporting the ADHC program and its registrants. If the staff in question works primarily for the nursing home with which the program is affiliated, they may not be considered part of the ADHC direct staff. 

Q: Can I support the education and certification of my current staff to become HHAs to work in my program? 

A: Yes. 

Q: Can I provide a comprehensive training course to my staff? 

A: Yes, as long as it is relevant to the work of the ADHC and supplements existing required or offered trainings and is provided by an external entity. An update to previous guidance is that training materials do not have to be cleared by the Department prior to use but should be included in documentation submitted as part of quarterly reporting for the period in which they are implemented. Covered topics may include person-centered planning, cultural competency, and trauma informed support, among other options. 

Q: Can I purchase bus passes, metro cards or other transportation supports to assist my employees in getting to and from the Center? 

A: Yes, you may cover these items as new employee benefits but may not purchase a car or van or hire a driver for this purpose. 

Service Support 

Q: Can my program purchase registrant-requested equipment that supports person-centered activities at the Center? 

A: No, equipment is not an allowable use of these grant funds.  See p. 8 of the Initial Guidance Document found at:https://www.health.ny.gov/health_care/medicaid/redesign/hcbs/enhanced_funding/2024/docs/arpa_adhc_guidance.pdf. Community integration must be person-centered and opportunities for individualized community integration must be considered. Group activities at the Center or even group outings in the community when participation is limited to program participants, even if supported by the interests of the registrants, are not the same as community integration which is an opportunity to interact with the broader community in a way that reflects the interests and goals of the residents as a group or individually. 

Q: Can I purchase cooking supplies to provide cooking classes to registrants that expressed an interest in becoming more independent in their IADLs related to meal preparation in their person-centered service plans? 

A: Yes, these supplies must remain at the Center and the activities must be consistent with those in registrants’ person-centered service plan goals and interests. 

Q: Can I purchase exercise equipment for use by the staff as part of a wellness initiative as well as by registrants to support strength and flexibility so they can take advantage of community integration? 

A: Yes, these supplies must remain at the Center and the activities must be consistent with those in registrants’ person-centered service plan goals and interests. 

Q: Can I sponsor community events at the Center to integrate registrants with the broader community? 

A: Yes, as long as participation is voluntary and consistent with the registrants’ person-centered service plan goals and interests. 

Q: Can I plan outings around cultural heritage or tributes to community members that have made a difference in registrants’ lives? 

A: Yes, as long as participation is voluntary and consistent with the registrants’ person-centered service plan goals and interests. 

Q: Can I purchase subscriptions? 

A: Further specificity is needed to address this question. To reiterate, the purpose of this funding is to ensure sufficient quality workforce to sustain and expand the ADHC program. Because ADHC programs have struggled to comply with community integration requirements under the Home and Community Based Services Final Rule issued by CMS in 2014, program sites are permitted to use some of these funds to meet the expectation that registrants may access the broader community to participate in activities identified in the person-centered service plan. However, unless the subscription involves a specific person-centered interest or goal related to community integration (at an individual level), it is likely not an allowable expense. 

Q: Can I purchase bus passes, metro cards or other transportation supports to facilitate individualized community integration? 

A: Yes, you can establish trip vouchers, purchase fares on public transportation or otherwise support the cost of transportation to community sites. You may not, however, purchase a car or van or hire a driver fully funded by the grant. 

Q: What about technology to assist registrants in meeting specific goals identified in their person-centered service plan? 

A: Further specificity is needed to address this question, but as included in previous guidance, technology that must be integrated into building systems is not an eligible use of this funding. Other purchases may be allowed on a case-by-case basis as long as they are tied directly to a goal or interest in the person-centered service plan. ​​​​​​​

Emergency Preparedness 

Q; Can I purchase air filters to reduce the risk of spreading respiratory illnesses when masks are not an option (i.e. during meal time)? 

A: Yes, as long as they are not required to be integrated into the building systems, which would make them capital improvements which are not allowed. 

Q: Can I purchase additional uniforms to reduce transmission of germs through more frequent laundering? 

A: Yes. 

Contact: Meg Everett, meverett@leadingageny.org, 518 867-8871.