While its goals are commendable, we find that OPWDD’s draft plan doesn’t provide the analysis of “current and anticipated utilization” that the 5.07 statute requires, assess unmet needs for services, or propose initiatives sufficient to meet those needs to inform the Executive Budget. For example:

WORKFORCE EMERGENCY:

The true scale of the workforce shortage should be understood not by counting vacancies in an already depleted system, but by estimating how many more DSPs must be recruited to provide needed services for all people with IDD. We believe DSPs must earn a living wage for OPWDD to provide these services.

HOUSING:

The plan must include data on the current and future need for all types of residential services and housing supports, the housing resources that are currently available, and the investments required to close the gap. We believe that Family Care is too inherently unstable to be a long-term housing option.

SERVICE EVALUATION AND RATE SETTING:

There is no plan for ongoing evaluation of the identified assessment tool -- the CAS -- to ensure that it is accurately and completely capturing the needs of the population, despite numerous stakeholder concerns with current content and process.

CARE MANAGEMENT:

Care Managers are central to every attempt to satisfy an unmet need for eligibility or services, but the draft plan proposes no new initiatives to directly support their role or boost their recruitment and retention, even though their workforce emergency equals that of Direct Support Professionals’.

EMPLOYMENT:

NY lags most other states in employment rates for people with IDD. Our many recommendations for identifying and addressing unmet needs for employment services include improved coordination with the Departments of Labor and Education, performance measures, and regulatory flexibility.

SELF DIRECTION:

We offer detailed recommendations for reforming the Self Direction system to make it more accessible, sustainable, and responsive to individuals and families. We advocate that stakeholders play an active role throughout the ARPA-funded study.

DIVERSITY, EQUITY & INCLUSION (DEI):

We strongly support the agency’s DEI initiatives and recommend more refined data and more targeted collaboration with community-based organizations, DSPs and care managers.

DATA ACCESS and TRANSPARENCY:

It is essential that OPWDD prioritizes the assessment and disclosure of unmet needs and that the proposed Data Community of Practice includes individuals and family members.

MANAGED CARE:

Before moving forward with managed care, OPWDD should provide solid evidence to the legislature and stakeholders that managed care will primarily benefit the individuals with IDD and improve the quality of services from the individual- and family-caregivers’ perspectives.