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PRIORITY ALERT: Call Your State Legislators Today

As we are in the final days of FY 2025-26 State Budget negotiations, it is imperative that you CALL your State legislators in their Albany offices TODAY to urge them to:
  1. Increase Medicaid reimbursement rates to nursing homes by 20% to cover the cost of essential care
  2. Restore 15% in capital cuts to nursing homes
  3. Exempt nursing homes from the MTA Commuter Tax which has the potential to offset any Medicaid increase
To find your legislators’ Albany phone numbers, click here. It is critical that you act today as negotiations to finalize the State’s FY 2025-26 State Budget are still ongoing. Thank you. NYSHFA | NYSCAL CONTACTS: Stephen B. Hanse, Esq. President & CEO 518-462-4800 x11 Kristin A. DeVries, MA, MPP Director of Government Relations 518-462-4800 x14 Read More

Senate and Assembly One-House Budget Bills

The Senate and Assembly have advanced their One-House Budget bills and accompanying resolutions, setting forth their respective negotiating positions pertaining to the FY 2025-26 State Budget. The following is a preliminary summary... Read More

Senate and Assembly One-House Budget Bills

The Senate and Assembly have advanced their One-House Budget bills and accompanying resolutions, setting forth their respective negotiating positions pertaining to the FY 2025-26 State Budget. The following is a preliminary summary of some of the provisions either included or excluded in both House’s proposals affecting skilled nursing and assisted living providers. SKILLED NURSING FACILITIES Medicaid Reimbursement Rate:

Senate:  Increases in the total Medicaid reimbursement base rate, in the aggregate, by $600 million ($500 million in the total Medicaid rate; $100 million in the operating component of the rate; Governor’s proposal: $385 million).

Assembly: Increases the Medicaid reimbursement rate, in the aggregate, by $481.25 million.

Capital Rate for SNFs:

Senate: Restores the 10% capital rate cut as set forth in FY 2024-25 State Budget, beginning April 1, 2025.

Assembly: Restores the 5% capital rate cut previously enacted in 2020.

70/40 Staffing Rule:

Senate: Adds new language to amend the 70/40 staffing rule to clarify that any federal financial assistance would be excluded from the total operating revenue for accounting purposes.

Assembly: Does not address.

Rate Appeals:

Senate & Assembly: Both Houses amend the Governor’s sunset proposal and extend the $80 million cap on nursing home capital rate appeals to April 1, 2027.

Certified Medication Aides:

Senate & Assembly: Both Houses reject the Governor’s proposal to authorize certified medication aides to work in skilled nursing facilities.

Trend Factor:

Senate & Assembly: Both Houses extend the 0% trend factor through March 31, 2027.

Cash Receipts Assessment (CRA):

Senate & Assembly: Both Houses accept the Governor’s proposal to extend the 6% CRA program through March 31, 2029.

Notice of Material Transaction Requirements:

Senate & Assembly: Both Houses accept the Governor’s proposal to amend the length of time that a healthcare entity must submit a notice to the Department of Health, from 30 to 60 days, before the closing date of the transaction.

________________________________________________________________ ASSISTED LIVING PROGRAMS (ALPs) Medicaid Reimbursement Rate:

Senate: Increases the Medicaid reimbursement rate, in the aggregate, by $30 million for FY 2025-26 and every year thereafter (to be included in the Medicaid base rate; Governor’s proposal: $15 million).

Assembly: Increases the Medicaid reimbursement rate, in the aggregate, by $18.75 million, for FY 2025-26 and every year thereafter (to be included in the Medicaid base rate).

State Supplemental Program (SSP):

Senate: Does not address.

Assembly: Includes an 8% increase to the SSP rate for enhanced residential care (Congregate Care Level 3).

ALP Bed Need Methodology:

Senate & Assembly: Rejects the Governor’s proposal to amend the ALP bed need methodology on a case-by-case basis beginning April 1, 2026.

EQUAL Program:

Senate & Assembly: Both Houses accept the Governor’s proposal to eliminate the EQUAL program.

Temporary Operator Program:

Senate: Accepts Governor’s proposal to amend the temporary operator program for adult care facilities, including an extension of the length and number of terms they may serve.

Assembly: Rejects the Governor’s proposal.

________________________________________________________________ ADDITIONAL PROVISIONS Interstate Licensure Compact and Nurse Licensure Compact

Senate & Assembly: Both Houses reject the Governor’s proposal to expand the scope of practice for medical providers via both the ILC and NLC.

NYSHFA|NYSCAL will continue to provide updates as the FY 2025-26 State Budget negotiations progress. NYSHFA | NYSCAL CONTACTS:  Stephen B. Hanse, Esq. President & CEO 518-462-4800 x.11 Kristin DeVries, MA, MPP Director of Government Relations 518-462-4800 x.14 Carl J. Pucci Financial Consultant 518-462-4800 x.36 cpucci@nyshfa.org Read More

Governor Hochul’s 2025 State of the State Address

Governor Hochul delivered her fourth State of the State today before the Legislature in the Hart Theater at The Egg in Albany. The Governor set forth the theme for her remarks as, “Your Family, Our Fight.” Acknowledging workforce shortages, including within the healthcare sector, the Governor’s 2025 State of the State presentation laid out over 200 proposals, including the following:
  • Tackling family cost of living issues, including:
    • middle class tax cut for families making less than $323,000;
    • inflation refunds up to $500 based on eligibility;
    • expansion of the State’s annual child tax credit;
    • free school breakfast and lunch for students; and
    • expansion and repair of childcare facilities.
  • Supporting youth and families through the expansion of lactation services and access to vital nutrition programs;
  • Investing in safety and justice system reforms;
  • Creating jobs and driving economic development;
  • Tackling the mental health crisis, including loosening the standards for involuntary commitment and expansion of laws related to court-ordered assisted outpatient treatment for those with mental illness; and
  • Revitalizing downtown Albany.
In the Governor’s State of the State briefing book entitled “We Are NY,” the Governor includes a chapter entitled “Investing in Health,” which includes, among other things, the following healthcare proposals:
  • Expand the scope of practice for certified nursing assistants (CNAs) to administer medications in nursing homes;
  • Deploy State funding to support healthcare training programs under a new grant program with a distinct focus on nurse training programs;
  • Cover the cost of free community college for individuals ages 25-55 for high-demand degree occupations, including nursing;
  • Strengthen the State’s ability to collect data and perform in-depth market analysis on private practice mergers and acquisitions (similar to the current oversight of hospitals and nursing homes);
  • Direct the Department of Health to work with Medicaid managed care plans to increase the availability and adoption of integrated care options and limit non-integrated offerings, as well as analyze their populations through a health equity lens to determine the largest disparities in quality and outcomes;
  • Define emergency medical services (EMS) as an essential service and require counties to ensure all residents have access;
  • Allow Medicaid to cover “Hospital at Home” programs which would allow hospitals to deliver inpatient level care in patient homes in clinically appropriate circumstances;
  • Create a new Health Equity Regional Organization (HERO), through a $125 million federal Medicaid waiver, to support the design and development of new policies, interventions, and targeted investments to improve outcomes and reduce health disparities; and
  • Allow dental hygienists to practice in more settings.
As always, NYSHFA|NYSCAL will be sure to provide updates on these proposals, as well as the details of the Governor’s FY 2025-26 Executive Budget when it is unveiled next week. NYSHFA|NYSCAL CONTACT: Stephen B. Hanse, Esq. President & CEO 518-462-4800 x.11 shanse@nyshfa.org Kristin DeVries, MA, MPP Director of Government Relations 518-462-4800 x14 kdevries@nyshfa-nyscal.org Read More

Governor Vetoes SNF Closure Bill; Grieving Families Act

Two bills that NYSHFA has lobbied against were vetoed by the Governor this past weekend. S.2984 (Rivera) / A.3703 (Epstein) would have subjected skilled nursing facilities to closure requirements despite an explicit process already outlined in Public Health Law. Current law and ... Read More

Governor Vetoes Temporary Operator Bill

NYSHFA successfully opposed legislation (A.6034-B, Paulin)/S.9131, Rivera) that would broaden the definition of Public Health Law §2806-a to include nursing homes among the facilities that, in the event of financial instability and insolvency, and ... Read More

Legislative Facility Tours Don’t Have to Be Spooky!

The days might be getting shorter, but there are still ample opportunities for legislators to visit your facilities and meet with your staff and residents on issues that directly affect you as providers. Let the NYSHFA|NYSCAL team demystify the legislative facility tour experience and ... Read More

Governor Signs Bill on Posting of SNF Quality Ratings

The Governor signed legislation (ch.336 of the laws of 2024) on Friday that NYSHFA has remained opposed to that would require skilled nursing facilities to post their ratings for health inspections, staffing, and quality measures. This is in addition to ... Read More

Final Enacted FY2024-25 State Budget Released

The Legislature released the agreed upon Health and Mental Health (HMH) Article VII State Budget bill earlier today with voting set to begin mid-afternoon, coming weeks after the April 1 deadline. The following is a summary of some of the provisions included in the FY2024-25 Enacted State Budget affecting skilled nursing and assisted living providers. Medicaid Rate Increase For Skilled Nursing Facilities: The final Enacted State Budget increases the Medicaid reimbursement rate for skilled nursing facilities by $285,000,000 (State and federal share) for the period of April 1, 2024 through March 31, 2025. This amount equates to an approximate 4.38% Medicaid rate increase. There is no specific distribution methodology set forth in the bill language. This Medicaid rate increase is in addition to the 1% increase currently in effect and still pending payment to providers. For Assisted Living Providers: The final Enacted State Budget increases the Medicaid reimbursement rate for assisted living providers by $15,000,000 (State share) for the period of April 1, 2024 through March 31, 2025. This amount equates to an approximate 4% Medicaid rate increase. There is no specific distribution methodology set forth in the bill language. This Medicaid rate increase is in addition to the 1% increase currently in effect and still pending payment to providers. Managed Care Organization (MCO) Tax The final Enacted State Budget institutes an MCO provider tax to secure federal financial participation for Medicaid costs, issue regulations to implement the tax, and impose such tax as an assessment upon insurers, HMOs, and Medicaid MCOs. Further, the State Budget creates a healthcare stability fund to receive funds as a result of the MCO provider tax. Funds collected can be used to increase provider Medicaid rates and reimburse the general fund for incurred Medicaid expenditures, among other things. Case Mix Freeze The final Enacted State Budget includes the Governor’s original proposal to freeze the case mix date effective July 1, 2023 until full implementation of the Patient Driven Payment Model (PDPM) case mix methodology occurs. Capital Rate for SNFs and ALPs The final Enacted State Budget institutes an additional 10% capital rate cut for both SNFs and ALPs. This excludes pediatric residential health care facilities. Medicaid Rebasing The final Enacted State Budget does not include language to rebase Medicaid rates for SNFs and/or ALPs. MCO Uniform Rate Increase The final Enacted State Budget eliminates the 1% uniform rate increase paid by the State to Medicaid MCOs. Nursing Home Vital Access Provider Program (VAPAP) Includes the Governor's proposal to decrease nursing home VAPAP funding from $100M to $25M annually. Special Needs Assisted Living Residence Voucher Program Makes permanent the SNALR voucher program and removes any caps to vouchers as previously proposed, subject to appropriation. This program subsidizes payments for individuals with Alzheimer’s and other forms of dementia who reside in a SNALR, up to 75% of their cost. It was originally instituted as a demonstration program and new applications were paused in July 2023 due to overwhelming demand. Assisted Living Quality Reporting Standards Does not include provisions to create quality reporting standards and accreditation processes for ALRs. ADDITIONAL PROVISIONS: Certified Medication Aides The final Enacted State Budget does not include provisions to allow certified medication aides to work in SNFs. This will likely be addressed as a post-Budget issue (A.8299, Clark/S.8635, Cooney). Interstate Licensure Compact and Nurse Licensure Compact Not included. Consumer-Directed Personal Assistance Program (CDPAP) The final Enacted State Budget creates a statewide fiscal intermediary (FI) for CDPAP to control exponential growth and fraudulent practices. The statewide FI may contract with at least one entity per rate setting region that has a proven track record of delivery services to elderly populations. Payments to subcontracted entities will be made by the statewide FI and all subcontractors must register with the State. Telehealth Extension The final Enacted State Budget extends the provisions relating to reimbursement for commercial and Medicaid telehealth services from April 1, 2024 to April 1, 2026. Cost-of-Living Adjustment (COLA) The final State Enacted Budget includes a 2.84% cost of living adjustment (COLA) for certain housing programs to account for inflationary trends. Programs eligible include OMH, OPWDD, OASAS, and SOFA-licensed facilities. Additionally, the final State Budget includes a 1.7% COLA salary increase for eligible workers. Statewide Healthcare Safety Transformation Program The final Enacted State Budget creates this Program to support safety net hospitals to improve access, equity, quality, and outcomes. While applicable to hospitals, skilled nursing facilities and other healthcare entities may serve as partner organizations to the safety net hospital and thereby by able to receive an award as part of this collaborative relationship to transform the hospital. NYSHFA | NYSCAL will continue to provide updates as further FY 2024-25 State Budget information becomes available. NYSHFA | NYSCAL CONTACTS:  Stephen B. Hanse, Esq. President & CEO 518-462-4800 x11 Kristin DeVries, MA, MPP Director of Government Relations 518-462-4800 x14 Carl Pucci Financial Consultant 518-462-4800 x36   Read More

SSI Rate Increase Bill Introduced in NYS Senate

At the request of NYSCAL, Senator Roxanne Persaud, Chair of the Senate Social Services Committee, has introduced legislation (S.8767) to increase the SSI rate for enhanced residential care settings (Congregate Care Level 3) by 10%. An SSI rate increase... Read More

Senate and Assembly One-House Budget Bills - (R.1952; S.8307-B / E.948; A.8807-B)

The Senate and Assembly have advanced their One-House Budget bills and accompanying resolutions, setting forth their respective negotiating positions pertaining to the FY 2024-25 State Budget. The following is a summary of some of the provisions either included or excluded in both House’s proposals affecting skilled nursing and assisted living providers. Medicaid Rate Adequacy For SNFs:

Senate: Increases the Medicaid reimbursement rate by 9.5% (6.5% increase plus 3% across the board).

Assembly: Increase the Medicaid reimbursement rate by 10.5% (7.5% increase plus 3% across the board).

For ALPs:

Senate: Increases the Medicaid reimbursement rate by 9.5% (6.5% increase plus 3% across the board).

Assembly: Increase the Medicaid reimbursement rate by 10.5% (7.5% increase plus 3% across the board).

Medicaid Rebasing

Senate: Adds new language to support Medicaid rate rebasing by January 1, 2026 and no less than every five years thereafter.

Assembly does not address.

Medicaid Base Rate for ALPs

Senate: Adds language to increase the base Medicaid rate for ALPs to 2022 levels and regularly thereafter to align with preexisting statute (50% of the cost for SNFs), for facilities with less than 300 beds.

Assembly: Does not address.

Capital Rate for SNFs

Senate & Assembly: Both reject the Governor’s proposal to institute a 10% capital rate cut.

Case Mix Freeze

Senate: Rejects the Governor’s 30-day amendment proposal to change the case mix freeze date from January 1, 2024 to July 1, 2023.

Assembly: Modifies the Governor’s 30-day amendment proposal to change the case mix freeze date from January 1, 2024 to July 1, 2023 “to establish a rate freeze on the operating component of skilled nursing facility rates until a new case mix methodology is developed by amending the date of the freeze to October 1, 2023.” (NYSHFA is seeking clarification on this language.)

Certified Medication Aides

Senate & Assembly: Both reject the Governor’s proposal to authorize certified medication aides to work in skilled nursing facilities.

Vital Access Provider Assurance Program

Senate: Adds $753 million to restore funding to Medicaid for programs such as the VAPAP.

Assembly: Provides $75 million to maintain the $100 million per year allocated to the Program.

Special Needs Assisted Living Residence Voucher Program

Senate: Includes the Governor’s proposal to make permanent the SNALR Voucher Program but eliminates the provision that calls for up to 200 vouchers to be issued. The Senate proposal also modifies the residency requirement.

Assembly: Includes the Governor’s proposal to make permanent the SNALR Voucher Program and modifies the residency requirement.

Assisted Living Quality Reporting Standards

Senate: Includes the Governor’s proposal to create quality reporting standards for ALRs, EALRs, and SNALRs, but amends language regarding the cadence of surveys which shall be performed by the Department on an unannounced basis for all facilities as opposed to 12-18 months for those facilities that receive advanced standing classification per the Governor’s proposal. Rejects the Governor’s language regarding nationally recognized accreditation.

Assembly: Rejects the Governor’s proposal to create quality reporting standards and accreditation processes for ALRs

Additional Provisions

Assembly: Adds language to create a Medicaid Investment Fund with revenue from the tax of managed care organizations for the funding of the non-federal share of investments in Medicaid that support healthcare delivery, among other things.

Senate & Assembly:  Rejects the Governor’s proposal to expand the scope of practice for medical providers and the introduction of the Interstate Licensure Compact and Nurse Licensure Compact.

Senate:  Adds $1.6 billion for the Statewide Health Care Facility Transformation Program (“Statewide VI”) to ensure geographical balancing of fund disbursement; and

Senate:  Adds $10 million to the Governor’s proposal to increase the personal needs allowance (PNA) for SNF residents.

NYSHFA | NYSCAL will continue to provide updates as the FY 2024-25 State Budget negotiations progress. NYSHFA | NYSCAL CONTACTS:  Stephen B. Hanse, Esq. President & CEO 518-462-4800 x11 Kristin DeVries, MA, MPP Director of Government Relations 518-462-4800 x14 Read More

NYSHFA Town Hall Call – 2/7/24

NYSHFA will be hosting a Town Hall call on Wednesday, February 7th at 11:00 am to discuss the latest legal, budgetary and legislative issues impacting skilled nursing providers throughout New York ... Read More

NYSHFA Town Hall Call – 2/7/24

NYSHFA will be hosting a Town Hall call on Wednesday, February 7th at 11:00 am to discuss the latest legal, budgetary and legislative issues impacting skilled nursing providers throughout New York ... Read More

NYSHFA’s Stephen Hanse, Esq. Testifies Before NYS Legislature

During Tuesday’s joint legislative FY 2024-25 Health Budget Hearing, NYSHFA|NYSCAL President & CEO, Stephen Hanse, Esq., made a passionate plea to the Legislature to infuse the Governor’s proposed budget with a Medicaid funding commitment for skilled nursing homes and assisted living programs. There is ... Read More

Assembly Moves ALR Quality Reporting Bill (A.5790-A, Paulin)

Last week, the Assembly Health Committee voted to move A.5790-A (Paulin)/No Same As out of the Committee. This bill authorizes the Department to develop a quality rating system to score results collected from facilities and annually report on quality measures. Facilities performing in the ... Read More

UPDATE: Governor Hochul’s FY 2024-25 Executive Budget Proposal

Please find the following summary of certain specific initiatives impacting Skilled Nursing and Assisted Living providers included within Governor Hochul’s $233 billion FY 2024-25 Executive Budget. Medicaid Global Cap Extension: Makes statutory changes necessary to extend the two-year Medicaid Global Cap budgeting construct through FY 2026. The Medicaid Global Cap is a mechanism to place limits on Medicaid spending for each fiscal year. Capped spending is indexed to the five-year rolling average of Medicaid spending projections within the National Health Expenditure Accounts produced by the Office of the Actuary within CMS. Capital Rate Cut: The Governor’s Executive Budget proposes to reduce the capital component of the Medicaid rate for skilled nursing facilities by 10%, effective April 1, 2024 (includes any facilities eligible to refinance their mortgage loans via the Shared Savings Program), for a projected State savings of $28.5 million in FY 2025 and 2026, respectively. Medicaid Operating Costs and Case Mix Acuity: Suspends updates to the January 1, 2024 operating component of the Medicaid rate for skilled nursing facilities while the Department develops a methodology for patient acuity using the Patient Driven Payment Model (PDPM), as previously noted by DOH. Effective October 1, 2023, CMS no longer collects the data that current law specifies to weight a base price for patient acuity levels. During the period of suspension, the Department will work with critical stakeholders and develop a methodology to drive reimbursement that is consistent with levels of patient need within nursing homes. This operating component suspension will remain in place until a new methodology is tested and approved. Allows for Certified Medication Aides in Nursing Homes Authorizes the utilization of medication aides in skilled nursing facilities so they can administer routine medications to residents under the supervision of an RN. Joint Interstate Compacts: Authorizes New York State to enter into two separate interstate licensure compacts for medical professionals: the Interstate Medical Compact for licensed physicians and the Interstate Nurse Licensure Compact for RNs and LPNs. Managed Care Proposals: Makes several programmatic changes to the State’s delivery of Medicaid benefits through managed care organizations, including removing Medicaid from the independent dispute resolution process; and requiring the State to procure Medicaid managed care benefits from Medicaid Managed Care plans, Managed Long Term Care plans, Medicaid Advantage Plus plans, and Health and Recovery Plans. Additionally, the Governor’s Executive Budget proposes to eliminate the 1% across the board administrative rate increase provided to Medicaid managed care organizations as a result of the FY 2022-23 Enacted Budget. Permanent Special Needs Assisted Living Residence (SNALR) Voucher Program: Transitions the voucher program from a pilot program to a permanent program. The SNALR Voucher Program has been a demonstration program since being authorized in 2018. The program subsidizes the cost of assisted living for individuals with Alzheimer’s disease and dementia who are not eligible for Medicaid. By remaining as a pilot program, the SNALR Voucher Program is without regulations to clearly define the expectations of the participating facilities. By making the SNALR Voucher program permanent, the Department of Health would be able to promulgate regulations to define expectations and ensure uniformity. Assisted Living Residence Quality Reporting: Requires assisted living residences (ALRs) to report annually on specific quality and cost measures to the Department, who will assign each ALR a quality score. Top scoring ALRs would receive a classification of advanced standing and reduced surveillance requirements (once every 12-18 months). Facilities without such classification would be surveyed on an unannounced basis, no less than annually. Further, the proposal would permit adult care facilities who provide assisted living services to seek accreditation from nationally recognized accreditation agencies and, for the period of such accreditation, be exempt from duplicate State inspection requirements. CONTACTS: Stephen B. Hanse, Esq. President & CEO 518-462-4800 x.11 shanse@nyshfa.org Kristin A. DeVries, MA, MPP Director of Government Relations 518-462-4800 x.14 kdevries@nyshfa-nyscal.org Carl J. Pucci Financial Consultant 518-462-4800 x36 cpucci@nyshfa.org Read More

Governor Hochul’s FY 2024-25 Executive Budget Proposal

On Tuesday, January 16, the Governor released her $233 billion FY2024-25 budget proposal, an all funds spending increase of 4.5% from last year.  Governor Hochul prioritized bolstering the State’s reserves, which currently sit at just over 15% of operating costs. The Executive Budget supports the implementation and expansion of various initiatives laid out in the Governor’s State of the State plan presented to the Legislature on January 9, 2024, and continues funding for existing commitments, including support for Medicaid and distressed hospitals and increases in the minimum wage. In FY 2025, Department of Health Medicaid spending is projected to total $30.9 billion, an increase of $3 billion (10.9%) from the revised FY 2024 levels, including over $1 billion in savings proposals. State-share Medicaid spending, including administrative costs, is projected to be $8.6 billion (39%) higher in FY 2025 than the levels recorded three years prior in FY 2022. Medicaid is the single largest category of Federal funding, representing 59% of Federal resources anticipated in the FY 2024-25 Executive Budget. The FY 2024-25 Executive Budget reflects the continuation of the Medicaid spending cap enacted in FY 2012, as updated, and recommends funding consistent with last year’s update to the allowable growth calculation. The Global Cap spending limit is set by the five-year rolling average of Medicaid spending projections within the National Health Expenditure Accounts produced by Office of the Actuary in the Centers for Medicare & Medicaid Services. Consistent with the index, the FY 2024-25 Executive Budget reflects $15.6 billion in additional Medicaid spending growth between FY 2024 and 2028 as compared to the prior Global Cap growth metric. The following is a summary of certain initiatives included within Governor Hochul’s FY 2024-25 Executive Budget:
  • Medicaid Rate Adequacy: No proposed decrease to rates. However, the Executive Budget calls on the State to maximize the use of available resources while working with long-term care stakeholders to identify at least $200 million in recurring State share savings across New York’s many long-term care programs (“Unallocated Reduction”)
  • Medicaid Section 1115 Demonstration Program Waiver: $7.5 billion in funding over the next three years ($6 billion Federal, $1.5 billion state) through an amendment to the 1115 demonstration program to support a comprehensive series of actions to advance health equity, reduce health disparities, and strengthen access to primary and behavioral health care through better integration of services. The waiver also includes $550 million in annual funding to support the transition of distressed providers to a new model of care utilizing global budgeting.
  • Cost-of-Living Adjustment: An additional annualized $3.4 million to provide a 1.5% COLA for State Office for the Aging programming.
  • Healthcare Workforce: CMS’ waiver amendment approval allows New York to make large investments across a series of wide-ranging Medicaid initiatives, including long-term, sustainable investments in the state’s health care workforce, including:
    • The establishment of innovative career pathway training programs for front-line health and social care professionals that will increase access to culturally appropriate services. These programs will train and educate for the purpose of creating a reliable healthcare workforce pipeline to address workforce shortages, as well as increasing opportunities for employment and career advancement; and
    • A loan repayment program for certain healthcare workforce professionals who commit to working in community-based practices in underserved areas, including dentists, psychiatrists, and clinical nurse specialists.
  • Out-of-State Nurses: Allows New York to join the Interstate Licensure Compact and Nurse Licensure so nurses and physicians licensed in other states may practice, either physically or virtually, in New York.
  • Certified Medication Aides: Allows for the expanded scope of practice for medication aides.
  • Certificate of Need (CON): Streamlining the certificate of need (CON) process.
  • Sunset the State's COVID-19 Sick Leave Law which required employers to provide sick leave and other benefits for employees subject to a mandatory or precautionary order of quarantine or isolation due to COVID-19 law because its applicability to new employers is unclear and quarantine requirements have changed.
  • Hate Crimes: Includes an increase of $10 million for the next round of the Securing Communities Against Hate Crimes (SCAHC) program, for a total of $35 million. The Executive Budget also includes legislation to expand the list of crimes eligible for prosecution as a hate crime.
  • Establish Assisted Living quality reporting and accreditation requirements to be published by the Department.
  • Make the Special Needs Assisted Living Residence (SNALR) program
  • Creation of an Elder Justice Coordinating Council tasked with developing strategies to defend elders from abuse.
NYSHFA|NYSCAL will continue to keep you updated as the FY 2024-25 Executive Budget progresses and negotiations with the Legislature begin. CONTACTS: Stephen B. Hanse, Esq. President & CEO 518-462-4800 x.11 shanse@nyshfa.org Kristin A. DeVries, MA, MPP Director of Government Relations 518-462-4800 x.14 kdevries@nyshfa-nyscal.org Read More

Governor Signs Clean Slate Act

Today, the Governor signed into law the Clean Slate Act (S.7551-A/A.1029-C; chap. 631, laws of 2023) which allows for certain criminal conviction records to be sealed after at least eight years for felonies, beginning from ... Read More

End of Session Update

The Legislative Session ended on Saturday, June 10 with the Assembly determining that it will need to reconvene sometime soon – possibly later this month – to debate and vote on outstanding legislation relative to casino gaming contracts. NYSHFA | NYSCAL wanted to provide you with updates on ... Read More

Nursing Home Quality Rating Legislation

Last week, the Assembly passed a bill (A.2188, Dinowitz/S.3498, Sanders) that would require nursing homes to post their ratings for health inspections, staffing, and quality measures, in addition to provisions already established that require posting of CMS quality ratings. NYSHFA ... Read More

Final FY 2023-24 New York State Budget Provisions

The final FY 2023-24 State Budget, as agreed upon by the Governor and Legislative Leaders this weekend, includes/excludes the below provisions that will impact skilled nursing and assisted living providers: SNF Medicaid Rate Increase Provides a uniform Medicaid rate increase of up to 7.5% for the operating component of nursing homes, subject to federal financial participation. ALP Medicaid Rate Increase Provides a uniform Medicaid rate increase of 6.5% for the operating component of assisted living programs, subject to federal financial participation.  Medicaid Global Cap Continues the Medicaid Global Cap through 2025. The metric used to set Medicaid Global Cap spending continues to be based on a five-year rolling average of Medicaid spending projections.  Cash Receipts Assessment (CRA) Continues the CRA at 6% through March 31, 2024 Statewide Health care Facility Transformation Program (“Statewide V”) Provides $990 million in grant funding for the creation of the Statewide V for the purpose of transforming, redesigning, and strengthening quality health care needs in nursing homes, adult care facilities, assisted living programs, and hospitals. $490 million is reserved for grants to health care providers for capital projects, debt retirement, working capital, or other non-capital projects that, among other things, increase access to care, improve quality of care, and ensure financial stability of health care providers. $500 million is reserved for investments in technological or telehealth projects, projects related to cybersecurity, and unfunded project applications submitted in response to Statewide IV.  Temporary Health Care Services Agencies Requires temporary health care services agencies to register annually with DOH and sets forth specific ownership and operational criteria that must be provided by each staffing agency to DOH. Additionally, the law sets forth minimum standards for agencies, that include, among other things, a requirement to maintain a written agreement with every health care entity in which in does business, that sets forth maximum rates that can be billed or charged; minimum license, training, and continuing education requirements for all assigned personnel; and submission to DOH of copies of all contracts and invoices between an agency and a health care entity. Moreover, the law further provides for:
  • DOH to promulgate regulations to implement the law, including establishing additional minimum standards regarding pricing, fees, administrative costs and business practices;
  • Agencies to report quarterly to DOH a full disclosure of charges and compensation, including a schedule of all hourly billing rates for each category of staff, and the names of all health care entities the agency has contracted with in the State;
  • DOH to maintain authority to examine the books and records of the agency;
  • DOH to be able to suspend, revoke or refuse to renew any staffing agency registration;
  • DOH to publish on its website a quarterly report containing aggregated and de-identified staffing agency data;
  • DOH and DOL to provide a report to the Governor and the Legislature by January 1, 2024 summarizing the key findings of the staffing agency data collected under the law; and,
  • The AG to bring an action for an injunction against any person who violates any provision of the law. 
70/40 Amendments While bill language agreed to by 1199 SEIU, NYSHFA, and several regional associations amending the 70/40 law with the goal of reducing the use of temporary staffing agencies in nursing homes was not included within the final State Budget, we anticipate this proposal to be introduced as a stand-alone bill in the Legislature. Disclosure of Material Transactions Creates a new article of law to set forth the definition of health care entities that must disclose material transactions to DOH to include “any other kind of health care facility, organization or plan providing healthcare services in this state.” Material transactions would include, among others:
  • Merger with a health care entity;
  • Acquisition of one or more health care entities;
  • Affiliation agreement/contract among health care entities; and,
  • Formation of a partnership or joint venture for the purpose of administering contracts with healthcare providers
The health care entity must submit a written notice and supporting documentation to DOH at least 30 days prior to a transaction closing date.  Medication Aides The FY 2023-24 State Budget does not include the Governor’s proposal for a two-year pilot program for the authorization of certified medication aides in nursing homes. However, we are actively pursuing pathways for a stand-alone bill in the Legislature. Assisted Living Survey and Reporting Requirements Omits the requirement for assisted living facilities to report to DOH annually on quality measures and other operational outcomes, in addition to new provisions regarding surveillance schedules and accreditation requirements. NYSHFA | NYSCAL will continue to provide updates on these and other FY 2023-24 State Budget issues as more information becomes available. NYSHFA | NYSCAL CONTACTS: Stephen B. Hanse, Esq. President & CEO 518-462-4800 x11 Kristin A. DeVries, MA, MPP Director of Government Relations 518-462-4800 x14 Carl Pucci 518-462-4800 x36 Read More

Senate and Assembly One-House Budget Bills

The Senate and the Assembly advanced their One-House Budget bills on March 14th setting forth their respective negotiating positions pertaining to the FY 2023-24 State Budget. The following is a brief summary of some of the provisions either included or excluded in each respective One-House Budget proposal affecting skilled nursing and assisted living providers. Senate One-House Budget Proposal (R.555)
  • Increases the Governor’s uniform Medicaid rate reimbursement increase from 5% to 10% for skilled nursing and assisted living facilities, adding $157.5 million. Further directs DOH to find solutions to ensure that staffing shortages do not result in underutilized nursing home beds;
  • Includes $2 million to support the Long-Term Care Ombudsman Program;
  • Adds $200 million to support the Statewide Health Care Facility Transformation Program (“Statewide V”);
  • Adds $187 million to support safe staffing for nursing homes;
  • Modifies the Governor’s proposal to reform the approval process for health care projects and transactions by accepting increased construction fees for hospitals, nursing homes, and diagnostic and treatment centers construction applications and exempting core public health services from home care licensure when provided by a local health department;
  • Modifies the Governor’s proposal requiring assisted living residences to report to DOH on quality measures which the Department will use to grant an advanced standing classification by omitting the provisions related to modified inspection schedules for facilities with advanced standing classification or that obtain accreditation from a nationally-recognized accreditor;
  • Does not include the Governor’s proposal to authorize certified nurse aides to administer medication-related tasks in skilled nursing facilities (certified medication aides) via a two-year pilot program;
  • Accepts the Governor's proposal to create minimum standards for temporary healthcare staffing agencies;
  • Does not include the Governor’s proposal to transfer oversight of healthcare professions from the State Education Department to NYSDOH; and,
  • Does not include the Governor’s proposal to expand the scope of practice for medical providers and the introduction of the Interstate Licensure Compact and Nurse Licensure Compact.
Assembly One-House Budget Proposal (E.190)
  • Increases the Governor’s uniform Medicaid rate reimbursement increase from 5% to 10% for skilled nursing and assisted living facilities, adding $157.5 million;
  • Includes the Governor’s proposal of $2.5 million for the Long-Term Care Ombudsman Program and provides an additional $12.5 million;
  • Provides $100 million in additional funding for financially distressed nursing homes;
  • Rejects the Governor’s proposal to require ALRs and EALRs to submit an annual report on quality measures to DOH and authorize DOH to grant new classifications based on assisted living quality reporting that would ease inspection requirements by including a description of quality measures and a process for getting consumer and provider input;
  • Instructs the Governor to begin the process of rebasing hospital, nursing home, and clinic Medicaid rates in FY 2024-25;
  • Modifies the Governor’s proposal to provide $1 billion through the Statewide Health Care Facility Transformation Program V (“Statewide V”) by establishing minimum funding amounts for community-based organizations;
  • Modifies the Governor’s proposal to establish a registration process for temporary health care services agencies and create minimum standards for temporary health care service agencies by including maximum rates that an agency can charge a facility;
  • Does not include the Governor’s proposal to authorize certain certified nurse aides to administer medication-related tasks in skilled nursing facilities (certified medication aides) via a two-year pilot program;
  • Does not include the Governor’s proposal to transfer oversight of healthcare professions from the State Education Department to NYSDOH; and,
  • Does not include the Governor’s proposal to allow New York to join the Interstate Medical Licensure and Nurse Licensure Compact.
NYSHFA | NYSCAL will continue to provide updates as the FY 2023-24 State Budget negotiations progress. NYSHFA | NYSCAL CONTACTS: Stephen B. Hanse, Esq. President & CEO 518-462-4800 x11 Kristin A. DeVries, MA, MPP Director of Government Relations 518-462-4800 x14 Read More

NYSHFA Legislative Visitation Days – Conference Call

NYSHFA will be holding a conference call for confirmed Legislative Visitation Day participants on Wednesday, February 22, 2023 at 2:00 pm. An email will be sent to participants with a call-in number. If you are not registered for lobby day, please do so by COB Wednesday, February 22! If you still wish to participate in lobby day, send an email to Nancy Knapp at nknapp@nyshfa.org ... Read More

NYSHFA Legislative Visitation Days

NYSHFA will be conducting our Legislative Visitation Days on Monday, February 27th (12:00 pm – 5:00 pm) and Tuesday, February 28th (9:00 am – 3:00 pm) to advocate for our issues within the FY 2023-24 State Budget ... Read More

NYSHFA Legislative Visitation Days

NYSHFA will be conducting our Legislative Visitation Days on Monday, February 27th (12:00 pm – 5:00 pm) and Tuesday, February 28th (9:00 am – 3:00 pm) to advocate for our issues within the FY 2023-24 State Budget ... Read More

FY 2023-24 Executive Budget Update

Following up on today’s NYSHFA|NYSCAL Town Hall Call, please find the following summary of certain initiatives impacting skilled nursing and assisted living providers included within Governor Hochul’s $227 billion FY 2023-24 Executive Budget. Medicaid Rate Increase Effective April 1, 2023 and thereafter, this proposal would amend Part I of Chapter 57 of the laws of 2022 to provide a uniform rate increase of 5% to residential health care facilities and assisted living programs. Provide Transformative Health Care Capital Funding The Public Health Law is amended by adding a new section 2825-h. This provides $1 billion in capital funding for the creation of a new Statewide Health Care Facility Transformation Program (“Statewide V”) for nursing homes, adult care facilities and hospitals, and other providers, for capital projects that, among other things, increase access to care, improve quality of care, ensure financial stability of health care providers; or invest in technological or telehealth projects. Up to $500 million would be awarded to health care providers in support of projects which promote innovative, patient-centered models of care, increased access to care, improved quality of care, and provider financial sustainability. Up to $500 million would also be awarded to health care providers for the implementation or improvement of critical health care information technologies and telehealth capacity. Nursing Home Appeals This proposal would amend Chapter 49 of the Laws of 2017, extending the limit on payment of nursing home appeals of eighty million dollars annually through April 1, 2027. Upper Payment Limit This proposal would amend Chapter 56 of the Laws of 2020, extending the nursing home upper payment limit and intergovernmental transfer provisions through March 31, 2026. Medicare Maximization This proposal would amend Chapter 56 of the Laws of 2020, extending the Nursing Home Medicare Maximization program through February 1, 2026. Trend Factor Elimination This proposal would amend Chapter 57 of the Laws of 2021, extending the elimination of the trend factor for service for general hospital and nursing home reimbursement through March 31, 2025. Cash Receipts Assessment This proposal would amend Chapter 57 of the Laws of 2021, extending the health facility 6% cash receipts assessment program through March 31, 2025. Nurse Staffing Agency Requirements This proposal would make statutory changes to require nurse staffing agencies to register and report key data about their operations with the goal of increasing transparency into the utilization and costs of contract labor. The data would aid the State in exploring options to remedy dependence on temporary healthcare services agency staffing. This proposal would add a new Article 29-K to the Public Health Law regarding the registration of temporary health care services agencies with the DOH; establishes staffing agency standards; requires all staffing agency rates to be reported on a quarterly basis; requires disclosure of the maximum rates that can be billed or charged by an agency, as well as the percentage of health care entity dollars that the agency expends in comparison to the agencies profits and other administrative costs; prohibits the imposition of liquidated damages or employment fees if temporary worker is hired by provider; authorizes the DOH to revoke staffing agency licenses; authorizes the DOH to request the Attorney General to bring a cause of action against a staffing agency; requires a report to be drafted by the DOH and the DOL and delivered to the Governor and the Legislature by 3/31/24. Medication Aides This proposal would amend the Education Law and Public Health Law to authorize certified medication aides to administer routine and prefilled 40 medications in residential health care facilities for a duration of two years (a temporary pilot program). Out of State Doctors and Nurses This proposal would amend the Education Law to allow New York to join the Interstate Medical Licensure Compact and the Nurse Licensure Compact, enabling doctors and nurses to relocate to New York and use their existing license to practice in the State. Section 32 of this bill would amend the Education Law to authorize issuance of temporary permits to practice for individuals licensed in another state who seek licensure in New York State. Minimum Wage This proposal would index the state minimum wage to the rate of inflation, subject to a cap and limited exceptions. Amends Section 652 of the Labor Law requiring indexing of the minimum wage regionally for inflation and allocates funds for the cost for State service providers. Such adjusted minimum wage rate shall be determined by increasing the current year’s minimum wage rate by the lesser of 3% and the rate of change in the average of the most recent period between the first of August and the thirty-first of July over the preceding 12 months published by the consumer price index for Northeast region urban wage earners and clerical workers. Public Health & Health Planning Council (“PHHPC”) Reduces from 10 to 7 years the PHHPC character and competence look back review period for certain CON applications; eliminates PHHPC review for transfers of interest of less than 10%; raises the cost threshold for projects that need to file a CON with the DOH; and revises the definition of “public need.” Non-Medical Transportation Establishes a working group to recommend ways to expand access to non-emergency medical transportation. Nurse Scholarships Expands scholarship funding for the ”Nurses For Our Future” program. Healthcare IT Supports the replacement of the State’s healthcare reporting infrastructure with a “nation leading” health monitoring and surveillance system. Wadsworth Center Provides $967 million for the reconstruction and consolidation of the Wadsworth Center. Assisted Living Quality Standards The Governor’s FY 2023-24 Executive Budget proposes two new quality initiatives. The first quality initiative proposal adds a new subdivision to the Public Health Law that applies to ALRs, SNALRs and EALRs and requires these facilities to self-report on an annual basis on quality measures. Adult Homes, Enriched Housing Programs and ALPs are excluded. From this quality reporting, the Department will assign a score to the results based on quality indicators developed by the Department. Under this proposal, assisted living providers will also be required to post their monthly service rates, staffing, the approved admission/residency agreement and a summary of all service fees on the facility’s website and also in a public area within the facility. This information would be made available to the public on forms that will be developed by the Department. The second quality initiative proposal amends the Social Services Law and applies to all Adult Care Facilities. This standard is different than the first proposal and is based on an accreditation by an outside agency.  The DOH will not be scoring the ACFs or relying on self-reported data. Those that have obtained accreditation and who meet eligibility criteria may, at the discretion of the Commissioner, be exempt from a Department inspection for the duration the accreditation is in good standing. If a facility accreditation is lost, the facility must report the loss to the Department within 10 business days and will no longer be exempt from inspection. Under this proposal, those facilities with top scores will be classified as “Advanced Standing” on their annual surveillance schedules and will be surveyed every twelve to eighteen months, with those receiving the highest rating being inspected at least once every 18 months. All other facilities not receiving that classification will be surveyed on an unannounced basis, but no less than annually. The Department will post the results of the quality reporting on its website. This proposed initiative will not affect the Department’s present methodology for conducting complaint surveys. NYSHFA|NYSCAL will continue to keep you updated as the FY 2023-24 Executive Budget progresses and negotiations with the Legislature begin. NYSHFA/NYSCAL CONTACTS: Stephen B. Hanse, Esq.` President & CEO 518-462-4800 x11 Read More

NYSHFA Legislative Visitation Days

NYSHFA will be conducting our Legislative Visitation Days on Monday, February 27th (12:00 pm – 5:00 pm) and Tuesday, February 28th (9:00 am – 3:00 pm) to advocate for our issues within the FY 2023-24 State Budget ... Read More

NYSHFA Legislative Visitation Days

NYSHFA will be conducting our Legislative Visitation Days on Monday, February 27th (12:00 pm – 5:00 pm) and Tuesday, February 28th (9:00 am – 3:00 pm) to advocate for our issues within the FY 2023-24 State Budget ... Read More

Governor Hochul’s FY 2023-24 Executive Budget Proposal

On Wednesday, February 1st, Governor Hochul released her $227 billion FY 2023-24 Executive Budget proposal. As presented, the FY 2023-24 Executive Budget increases “All Funds” State spending by an estimated 2.4% and continues the Medicaid Global Cap through 2025. The metric used to set the Medicaid Global Cap spending continues to be based on a 5-year rolling average of Medicaid spending projections. The Governor’s Executive Budget reflects $11 billion in additional Medicaid spending growth between FY 2023 and FY 2027. In presenting the Executive Budget, Governor Hochul emphasized that last year’s Executive Budget included the largest investment in healthcare in the State’s history and that she is “doubling down” on that investment with her FY 2023-24 Executive Budget. Specifically, in FY 2024, the State funded portion of the Medicaid program will be the largest in State history at $34.7 billion with 7.9 million expected enrollees by June 2023. The following is a brief summary of certain initiatives included within Governor Hochul’s FY 2023-24 Executive Budget:
  • Medicaid Rate Increase: Provides a 5% increase ($157.5 M State Share) in the operating component of a nursing home’s Medicaid rate effective April 1, 2023. Provides a 5% increase in the Medicaid rate for assisted living providers as well;
  • Capital Funding: Provides $1 billion in capital funding for the creation of a new Statewide Health Care Facility Transformation Program (“Statewide V”) for nursing homes, adult care facilities and hospitals, and other providers, for capital projects that, among other things, increase access to care, improve quality of care, ensure financial stability of health care providers; or invest in technological or telehealth projects;
  • Nurse Staffing Agency Requirements: Requires health care staffing agencies to register with the DOH; establishes staffing agency standards; requires all staffing agency rates to be reported on a quarterly basis; prohibits the imposition of liquidated damages or employment fees if temporary worker is hired by provider; authorizes the DOH to revoke staffing agency licenses; authorizes the DOH to request the Attorney General to bring a cause of action against a staffing agency; requires a report to be drafted by the DOH and the DOL and delivered to the Governor and the Legislature by 3/31/24;
  • Medication Aides: Allows for nursing homes to utilize medication aides;
  • Out of State Nurses: Allows New York to join the Interstate Licensure Compact so nurses and physicians licensed in other states may practice, either physically or virtually, in New York;
  • Assisted Living Survey Requirements: Requires assisted living facilities to report annually on quality measures; post monthly services rates, staffing, residency agreements and summaries of fees; authorizes DOH to post results of assisted living facility quality reporting; top rated facilities would be granted the classification of advanced standing on their annual surveillance schedules; advanced standing facilities would be surveyed every 12 to 18 months, while all other assisted living facilities would be surveyed on an unannounced basis annually; assisted living facilities that receive national accreditation may be exempted by the DOH from surveys during the duration of their accreditation;
  • Minimum Wage: Indexes the minimum wage regionally for inflation and allocates funds for the cost for State service providers.
  • Public Health & Health Planning Council (“PHHPC”): Reduces from 10 to 7 years the PHHPC character and competence look back review period for certain CON applications; eliminates PHHPC review for transfers of interest of less than 10%; raises the cost threshold for projects that need to file a CON with the DOH; and revises the definition of “public need;”
  • Non-Medical Transportation: Establishes a working group to recommend ways to expand access to non-emergency medical transportation;
  • Nurse Scholarships: Expands scholarship funding for the ”Nurses For Our Future” program;
  • Healthcare IT: Supports the replacement of the State’s healthcare reporting infrastructure with a “nation leading” health monitoring and surveillance system; and
  • Wadsworth Center: Provides $967 million for the reconstruction and consolidation of the Wadsworth Center.
NYSHFA|NYSCAL will continue to keep you updated as the FY 2023-24 Executive Budget progresses and negotiations with the Legislature begin. NYSHFA/NYSCAL CONTACTS: Stephen B. Hanse, Esq. President & CEO 518-462-4800 x11 Tarrah Quinlan, RN, BSN Director of Education Program Development and Member Operations 518-462-4800 x20 Carl J. Pucci 518-462-4800 x36 Read More

NYSHFA Legislative Visitation Days

NYSHFA will be conducting our Legislative Visitation Days on Monday, February 27th (12:00 pm – 5:00 pm) and Tuesday, February 28th (9:00 am – 3:00 pm) to advocate for our issues within the FY 2023-24 State Budget ... Read More

NYSHFA Legislative Visitation Days

NYSHFA will be conducting our Legislative Visitation Days on Monday, February 27th (12:00 pm – 5:00 pm) and Tuesday, February 28th (9:00 am – 3:00 pm) to advocate for our issues within the FY 2023-24 State Budget. These meetings will be in-person this year. We will provide additional meeting details as time gets closer. Please send an email to Nancy Knapp at nknapp@nyshfa.org if you will be attending this year’s Legislative Visitation Days. Also, if you have specific legislators you would like to meet with during these dates, please include that in your email to Nancy. For overnight accommodations, please call the Hilton Hotel, 40 Lodge Street, Albany, NY at 518-462-6611. The current rates start at $219 for the evening of February 27. Unfortunately, we do not have a block of rooms, so please book your accommodations quickly! NYSHFA/NYSCAL CONTACTS: Stephen B. Hanse, Esq.` President & CEO 518-462-4800 x11 Nancy Knapp Administrative Assistant 518-462-4800 x26 Read More

Governor Hochul’s 2023 State of the State Address

Governor Hochul delivered her second State of the State today before a joint Session of the Legislature in the Assembly Chamber in the State Capitol in Albany. In her remarks, which lasted for roughly one hour, Governor Hochul highlighted six issue areas:
  • Crime and gun violence;
  • Mental health issues;
  • Access to affordable housing;
  • Energy costs and climate change;
  • Access to childcare services; and
  • Indexing the State’s regional minimum wages to inflation with a cap and an “off ramp” in the event of certain economic conditions.
The Governor did not mention either skilled nursing or assisted living providers during her remarks. The Governor did highlight a proposal to establish 3,500 new residential units for New Yorkers with mental illness. Additionally, the only reference the Governor made to hospitals was during her remarks regarding access to mental health services, where the Governor criticized hospitals for receiving $27.5M in the FY 2022-23 enacted State Budget for expanding the number of beds available for mental health patients and failing to bring these beds on line. In the Governor’s printed State of the State briefing book entitled “Achieving the New York Dream,” the Governor includes a section (Section IV) entitled “Building a Health Care System for New York’s Future,” which includes, among other things, the following proposals:
  • Establish quality reporting and accreditation for assisted living residences and implement quality improvement initiatives in nursing homes “to promote transparency and make it easier for New Yorker’s to make informed choices;”
  • Establish a Commission on the Future of Health Care to, among other things, shape the allocation strategy of subsidies for financially distressed nursing homes and hospitals and health care capital;
  • Require the DOH to launch an initiative to automate data reporting, reduce the administrative burden on providers, and provide greater flexibility to the DOH on the types and frequency of data collection;
  • Advance legislation to require staffing agencies to register and report key data about their operations in an effort to increase transparency into the utilization and costs of contract labor;
  • Expand existing transformative capital funding and establish a new capital grant fund to enable technological upgrades;
  • Advance legislation to allow New York to join the Interstate Licensure Compact and the Nurse Licensure Compact;
  • Require the DOH to review and amend the CON process, including raising the cost threshold for projects that need to file a CON, and revisiting the definition of “public need” used in the application process;
  • Create a comprehensive plan to address excessive medical debt for patients, including (1) amending the Consumer Credit Fairness Act to cover medical debt; (2) launching an industry and consumer education campaign; and (3) requiring hospitals to use a uniform application form; and
  • Establish a working group to recommend ways to expand access to non-emergency medical transportation.
As always, NYSHFA|NYSCAL will be sure to provide updates on these and other initiatives as the FY 2023-24 State Budget process moves forward. NYSHFA/NYSCAL CONTACTS: Stephen B. Hanse, Esq.` President & CEO 518-462-4800 x11 Read More

Reminder: Early Voting Begins October 29th

This is a reminder that early voting for the General Election will take place October 29 through November 6, 2022. All registered voters are eligible to participate in the General Election. You can also vote on November 8th which is General Election Day... Read More

Public Health and Health Planning Council

On Friday, September 30th, of the Public Health and Health Planning Council (“PHHPC”) released its respective agendas for the October 6th PHHPC Codes Committee meeting and the full October 6th PHHPC meeting. Absent from both agendas were the proposed regulations drafted by the DOH to implement the provisions of Public Health Law §§ 2828 and 2895-b, which ... Read More

IMPORTANT REMINDER: Comments to the Public Health and Health Planning Council (PHHPC)

Attached is a revised PHHPC comment letter prepared by NYSHFA regarding the draft 70/40/5 Spending and 3.5 Staffing Mandate regulations. This revised draft letter does not require facility specific financial data. If you haven't done so already, please take the time to complete the letter and submit to PHHPC. Also, below is a link to NYSHFA’s VoterVoice where you can electronically submit your comments to PHHPC. If you are sending a hard copy letter, it is imperative that a copy of your PHHPC comment letter also be emailed to Comments@nyshfa.org. It is imperative that you complete this letter ASAP and e-mail it to PHHPC. Click the link below to log in and send your message: https://www.votervoice.net/NYSHFA/Campaigns/97171/Respond NYSHFA/NYSCAL CONTACTS: Stephen B. Hanse, Esq. President & CEO 518-462-4800 x11 Read More

Comments to the Public Health and Health Planning Council (PHHPC)

NYSHFA hosted an Town Hall Call today regarding the submission of public comments by all NYSHFA members to the Public Health and Health Planning Council (“PHHPC”) opposing both the revised proposed 70/40/5 spending mandate and 3.5 hours staffing mandate regulations. Attached is an updated draft PHHPC comment letter prepared by NYSHFA that was discussed during the Town Hall Call. Also, below is a link to NYSHFA's VoterVoice where you can electronically submit your comments to PHHPC. If you are send a hard copy letter, it is imperative that a copy pfyour PHHPC comment letter also be emailed to Comments@nyshfa.org. Click the link below to log in and send your message: https://www.votervoice.net/NYSHFA/Campaigns/97171/Respond NYSHFA/NYSCAL CONTACTS: Stephen B. Hanse, Esq.` President & CEO 518-462-4800 x11 Read More

Urgent NYSHFA - Town Hall Call

On Tuesday, August 23rd at 3:00 PM, NYSHFA will be hosting an important Town Hall Call regarding the submission of public comments by all NYSHFA members to the Public Health and Health Planning Council (“PHHPC”) opposing both the revised proposed 70/40/5 spending mandate and 3.5 hrs staffing mandate regulations...   Read More

Urgent NYSHFA - Town Hall Call

On Tuesday, August 23rd at 3:00 PM, NYSHFA will be hosting an important Town Hall Call regarding the submission of public comments by all NYSHFA members to the Public Health and Health Planning Council (“PHHPC”) opposing both the revised proposed 70/40/5 spending mandate and 3.5 hrs staffing mandate regulations. Call In # 1-800-220-9875 Participant Code:  14227658 Please make every effort to participate on this important NYSHFA Town Hall Call. Thank you! NYSHFA/NYSCAL CONTACTS: Stephen B. Hanse, Esq.` President & CEO 518-462-4800 x11 Read More

Register now for the AHCA/NCAL Congressional Briefing

Get the latest news about what’s happening on the Hill, network with colleagues, hear from exciting speakers, and earn CEs at this event. It’s more important than ever to make sure that your Members of Congress understand the challenges you face on a daily basis. The registration deadline is April 29, 2022 ... Read More

FY 2022-23 Executive Budget Overview

1.5% Medicaid Cut Restoration Restores the prior administration’s 1.5% reduction to FFS Medicaid revenue in order to provide additional funding and recognize growth in provider service costs. 1% ATB Medicaid Rate Increase Provides for a payment increase of 1% across all DOH Medicaid fee-for-service rates. Healthcare Workforce Bonuses Amends the Social Services Law to make statutory changes necessary to implement healthcare workforce bonuses. Specifically, the law will be amended to provide health and mental hygiene workers earning up to $100,000 annually with a one-time bonus up to $3,000. The bill requires Medicaid providers to identify, claim, and pass through healthcare worker bonuses, and establishes monetary penalties for such providers for failure to properly do so. The bill further establishes that the maximum bonus per employee will be $3,000 and shall not be subject to state and local income tax. Statewide Facility Transformation Program IV Allocates $1.6B for the purpose of transforming, redesigning and strengthening health care needs. Supports capital projects that facilitates advancing these transformational goals.
  • Authorizes use of $450M to finance existing Program III eligible capital projects. This includes funds for residential health care facilities.
  • Invests an additional $50M to support implementation of a Green House Nursing Home Initiative.
  • Invests an additional $150M for IT infrastructure and telehealth capabilities for providers.
  • Allocates $61M additional funding for minimum staffing requirements.
70/40 Law Amendments Amends the definition of “revenue” in the 70/40 law to exclude the cash receipts assessment for all providers. Also amends the definition of “revenue” to exclude the capital per diem portion of the Medicaid rate for nursing homes that have a 4-Star or 5-Star CMS rating. Also allows for the Commissioner of Health, on a case by case basis, to exclude from the definition of “revenue” the capital per diem portion of the Medicaid rate for nursing homes that have a 3-Star CMS rating. Scope Of Practice: CertifiedMedication Aides Amends the Education Law and the Public Health Law to expand the Nurse Aide’s scope of practice to include the administration of medication in a skilled nursing facility. Specifically, the Education and Public Health Laws will be amended to allow Certified Nurse Aides to administer routine and prefilled medications (insulin, low weight molecular heparin, naloxone, and epinephrine) once trained and able to demonstrate competency. The Certified Medication Aide will be supervised by a Registered Professional Nurse employed by the skilled nursing facility. Facilities must have a systemic approach to address drug diversion. Financially Distressed Facilities Amends the Public Health Law to include residential healthcare facilities and adult care facilities among the providers that are eligible for Vital Access Provider Assurance Program (“VAPAP”) funds. Medicaid Global Cap Extends the Medicaid Global Cap for two years (through FY 2024). Modifies the metric for year-to-year growth allowed for Medicaid spending by adopting the five-year rolling average of Medicaid spending projections, based on the CMS Office of Actuarial Services (replaces the 10-year rolling average of the Medical component of the CPI index). The Executive Budget calls for a 4.7% increase in the Global Cap for FY 2022-23. Nurses Across New York Amends the Public Health Law to implement workforce initiatives to rebuild and grow the healthcare workforce, including establishing the Nurses Across New York (“NANY”) loan repayment program.  Specifically, Public Health Law will be amended to establish the NANY program which would reimburse nurses working in underserved communities for loan repayment over three years. A work group would be appointed from associations representing nurses, hospitals, and other healthcare providers to streamline the application process. Interstate Medical Licensure Compact Authorizes New York to join the Interstate Medical and Nurse Licensure Compact to allow doctors and nurses to easily relocate and practice in their profession using their existing license to practice in New York. Joining the Compact recognizes the expanded mobility of nurses and the need for coordination and cooperation among states to ensure the health and safety of residents and the benefits to public health through the effective use of advanced communication technologies. Also authorizes the issuance of a temporary permit for up to six months to practice while a licensing application in a qualified high need healthcare profession is pending for individuals licensed in another state who seeks licensure in New York while under the supervision of a New York licensee. Assisted Living Needs Methodology Extends the deadline that determines the need methodology for the Assisted Living Program through April 1, 2025. ACF regional and ALP occupancy rates will factor into the need methodology. Existing ALP Providers in good standing with the Department of Health will be afforded an expedited review when applying for an additional nine beds not requiring renovation or construction. Based on a complete and satisfactory application, a determination of the application will be made within 90 days of submission. Transfer of Oversight for Licensed Healthcare Professions Amends the Education Law and the Public Health Law in relation to the transfer of oversight of certain licensed professions from the State Education Department to the Department of Health. Provides that all functions, powers, duties and obligations of the Education Department concerning the healthcare professions listed in the bill which includes medicine, physicians, pharmacy, nursing, OT, PT, speech, social work, dietary and mental health among other healthcare professions will be transferred to NYS DOH. NYSHFA/NYSCAL CONTACTS: Stephen B. Hanse, Esq. President & CEO 518-462-4800 x11 Read More

Governor Hochul’s FY 2022-23 Executive Budget Proposal

On Tuesday, January 18th, Governor Hochul released her $216.3 billion FY 2022-23 Executive Budget proposal entitled “A New Era for New York.” As presented, the FY 2022-23 Executive Budget increases overall State spending by an estimated 3.1%, increases the Medicaid Global Cap ceiling to 4.7%, and changes the metric used to set the Medicaid Global Cap spending from the 10-year rolling average of the medical component of the CPI to a 5-year rolling average based on Medicaid spending projections. Total Federal, State and local Medicaid spending is expected to be $92 billion in FY 2023, an increase of 6.3%. In presenting the Executive Budget, Governor Hochul emphasized the critical need to invest in healthcare and rebuild New York’s healthcare workforce, highlighting that the FY 2022-23 Executive Budget includes $10 billion for healthcare – “the largest investment in healthcare in State history.” The following is a brief summary of certain initiatives included within Governor Hochul’s FY 2022-23 Executive Budget:
  • Restores the prior administration’s 1.5% Medicaid cut;
  • Increases the Medicaid base rate by 1% ATB;
  • Invests $1.2 billion (state share) for healthcare worker retention and recruitment by providing up to $3,000 per frontline healthcare worker earning up to $100k annually. Workers must have been employed a minimum of 6 months to be eligible. These funds will flow through the employer via Medicaid;
  • Allows for nursing homes to utilize medication aides;
  • Establishes a $1.6 billion capital program for financing capital improvements to nursing homes and other eligible healthcare facilities;
  • Allocates $450 million for other capital improvements, with $50 million guaranteed for nursing homes;
  • Invests $150 million to build out IT infrastructure and telehealth capabilities for various providers;
  • Allocates $61 million (state share) for minimum staffing requirements;
  • Invests $50 million to support the implementation of a Green House Nursing Home initiative; and
  • Allocates $750 million to construct a new laboratory on the Harriman campus in Albany.
NYSHFA|NYSCAL will continue to keep you updated as the FY 2022-23 Executive Budget bills are introduced and negotiations with the Legislature begin. NYSHFA/NYSCAL CONTACTS: Stephen B. Hanse, Esq. President & CEO 518-462-4800 x11 Read More

Governor Hochul’s State of the State Address

Governor Hochul delivered her first State of the State address today in the Assembly Chamber in the State Capitol in Albany. In speaking for just under an hour, Governor Hochul opened her speech by directly addressing the critical role of healthcare workers in hospitals and long-term care facilities and the healthcare workforce crisis New York is facing. Building upon these remarks, Governor Hochul set forth several proposals to rebuild and grow the State’s healthcare workforce by 20% over the next 5 years and invest $10 billion in healthcare. Key components of the Governor’s multi-year investment proposal include the following: $2 billion for healthcare worker wages; $2 billion for healthcare worker retention bonuses, including $3,000 bonuses going to certain full-time workers; $2 billion for healthcare capital infrastructure and improved lab capacity; and $500 million for certain COLAs. In addition, Governor Hochul also proposed the following long-term care initiatives in her State of the State: Allowing certain long-term care workers to administer medications in nursing homes; Establishing certification criteria for “memory care” that will require long-term care facilities to include specific training requirements for staff and administrators; Offering free tuition, cover instructional costs and provide stipends for high demand healthcare occupations; Developing career pathways for long-term care workers by investing in mentorship and transition tools; Supporting conversions of nursing homes to the Green House model for long-term care; Initiating a study of the impacts of COVID on the Long-Term Care Ombudsman Program; Establishing a State Master Plan for Aging through an Executive Order to address challenges related to communication, caregiving and financing; and Creating a Center for Medicaid Innovation to lower costs and improve care. As always, NYSHFA|NYSCAL will be sure to provide updates on these and other initiatives as the FY 2022-23 State Budget process moves forward. NYSHFA/NYSCAL CONTACTS: Stephen B. Hanse, Esq. President & CEO 518-462-4800 x11 Read More

Clarification: Executive Order 202.100

Governor Andrew Cuomo signed Executive Order (EO) 202.100 which is effective through April 30, 2021. This EO continues the suspensions and modifications of law made by EO 202, with the exception to temporarily suspend or modify any statute, local law, ordinance, order, rule, or regulation, or parts thereof, of any agency during a State disaster emergency, if compliance with such would prevent, hinder, or delay action necessary to assist or aid in coping with such disaster.  In addition to requiring the nursing home operators or administrators to certify that they are able to properly care for a patient and obtain a negative COVID-19 diagnostic test result prior to discharge from the hospital, it further requires that no Article 28 general hospital shall discharge a patient to a nursing home, without first offering to medically eligible patients, and if the patient consents, providing a COVID-19 vaccine to such patient. Please see attached Executive Order and Guidance that was sent to hospitals regarding Vaccinating Long-Term Care Patients Before Discharge to a Long-Term Care Facility. NYSHFA/NYSCAL CONTACTS: Stephen B. Hanse, Esq. President & CEO 518-462-4800 x11 Lisa Volk, RN, B.P.S., LNHA Director, Clinical & Quality Services 518-462-4800 x15 Read More

70/40 Spending Ratio - Executive Budget Summary

Included within the Health & Mental Hygiene State Budget bill (S.2507-C/A.3007-C), which is anticipated to be passed by the Legislature today, are the following provisions pertaining to the 70/40 nursing home spending ratio. As previously noted, O’Connell and Aronowitz, NYSHFAs General Counsel, anticipates filing suit to challenge these and other provisions in either or both state and federal court in order to invalidate the terms. NYSHFA will continue to provide updates as these issues progress.
  • Establishes minimum direct resident care spending thresholds effective on 1/1/22 where every RHCF must spend a minimum of 70 percent of revenue on direct resident care and 40 percent of revenue on resident facing staffing. Resident facing staffing is included within the amounts spent on direct resident care.
  • 15 percent of costs associated with resident facing staffing shall be deducted for contracted services provided by RNs, LPNs and CNAs.
  • RHCFs whose total operating revenue exceeds total operating and non-operating expenses by 5% or that fail to spend the minimum amount necessary to comply with the minimum spending standards for resident facing staffing or direct resident care, calculated on an annual basis, shall remit the difference to the State by 11/1 in the year following the year in which the expenses are incurred. Such funds shall be deposited into the Nursing Home Quality Pool.
  • “Revenue” is defined as total operating revenue from or on behalf of residents, government payers or third-party payers.
  • The definition of “Revenue” excludes the average increase in the capital portion of the Medicaid reimbursement rate from the prior 3 years.
  • “Expenses” are defined as including all operating and non-operating expenses before extraordinary gains. Third party transactions or compensation that is greater than the fair market value for such transactions and the payment of compensation for employees not actively engaged in or providing services at the facility are excluded from expenses.
  • “Direct Resident Care” is defined very broadly but excludes administrative costs (other than nurse administration), capital costs, debt service, taxes (other than sales taxes and payroll taxes), capital depreciation, rent and leases and fiscal services.
  • “Resident facing staffing” is defined as including all staffing expenses in the ancillary and program services categories on Exhibit H of the cost report as of 2/15/21.
  • Authorizes the Commissioner of Health to waive the requirements on a case-by-case basis, upon successful demonstration of unexpected or exceptional circumstances which prevent compliance.
  • Authorizes the Commissioner of Health to seek a State Plan Amendment and promulgate regulations to implement the law.
NYSHFA/NYSCAL CONTACTS: Stephen B. Hanse, Esq. President & CEO 518-462-4800 x11 Read More

Senate and Assembly One-House Budget Bills

The Senate and the Assembly advanced their One-House Budget bills setting forth their respective negotiating positions pertaining to the FY 2021-22 State Budget. The following is a summary of some of the provisions either included or excluded in each respective One-House Budget proposal affecting skilled nursing and assisted living providers. It is important to note that while the Senate and Assembly both rejected the Governor’s nursing home and adult care reforms, these initiatives are being advanced in legislation outside of the State Budget process by both the Senate and Assembly and could also be included in the final FY 2021-22 State Budget. Senate One-House Budget Proposal
  • Does not include the Governor’s proposed nursing home and adult care reforms stating that the Senate has already passed a package of nursing home reform legislation;
  • Does not include the Governor’s 1 percent Across the Board Medicaid reimbursement cut;
  • Does not include the Governor’s extension of the Medicaid Global Cap through FY 2023 and calls on the DOH to seek alternatives that factor in reductions in federal reimbursement rates, adjustments in utilization and enrollment increases;
  • Provides $200 million for services and expenses for acute care facilities and nursing homes to increase nurse staffing levels;
  • Does not include the Governor’s transfer of $455 million of Medicaid funds to the General Fund;
  • Does not include the Governor’s elimination of EQUAL subsidy program;
  • Expands the definition of ‘distant site’ to allow telehealth providers to provide services anywhere in the United States;
  • Repeals the transition of the Medicaid pharmacy benefit from Medicaid Managed Care; and
  • Adds language to require the DOH to reoffer contracts to ensure there are at least two fiscal intermediaries for CDPAP in each county with a population of 200,000 or more.
Assembly One-House Budget Proposal
  • Does not include the Governor’s proposal related to nursing homes and adult care facilities;
  • Does not include the Governor’s 1 percent Across the Board Medicaid reimbursement cut;
  • Transfers $250 million for distressed hospitals and nursing homes to the Medicaid general fund;
  • Provides $20 million for workforce recruitment and retention of nursing home CNAs and home care personal aides;
  • Does not include the Governor’s proposal to eliminate exemptions for mandatory electronic prescribing requirements;
  • Does not include the Governor’s elimination of EQUAL subsidy program;
  • Includes a proposal to establish the eligibility of individuals being discharged from a nursing home or adult home to the community for Special Standard for Housing Expenses which exempts an amount of income for the purpose of assisting with housing costs;
  • Restores funding for the Adult Home advocacy Program to support legal service providers assisting adult home residents;
  • Includes an additional $1 million in funding for the Long Term Care Ombudsman Program;
  • Carves out services for Medicaid enrollees with traumatic brain injuries or that qualify for nursing home diversion from Medicaid managed care and into Medicaid FFS;
  • Includes a proposal to require the DOH to conduct a study on ambulette Medicaid reimbursement rates;
  • Delays the Medicaid pharmacy transition from managed care to FFS for three years; and
  • Does not include the Governor’s proposal to eliminate Prescriber Prevails.
NYSHFA | NYSCAL will continue to provide updates as the FY 2021-22 State Budget negotiations progress. NYSHFA/NYSCAL CONTACTS: Stephen B. Hanse, Esq. President & CEO 518-462-4800 x11 Read More

Governor Cuomo's 2021 State of the State Address

Governor Andrew M. Cuomo presented his 2021 State of the State address today with the theme of “Reimagine, Rebuild, Renew.” The Governor used his 2021 State of the State address to provide an overview of seven policy area initiatives. The Governor announced that in the coming days he will follow up these initiatives with three additional presentations to further set forth the proposed action plans that will be included within the seven initiatives. Read More

2021/22 Executive Budget Summary

SKILLED NURSING FACILITIES  Global Cap  Extends the Medicaid global cap through state fiscal year 2022-23. Retains Medicaid spending within capped levels indexed to the ten-year rolling average of the medical CPI component.  Trend Factor  Continues the elimination of the annual Trend Factor for inpatient and outpatient services provided by general hospitals, SNFs, ALPs, ADHCs and HHC services through March 31, 2023. Cash Receipts Assessment  Continues the residential health care facilities gross receipts assessment at the existing 6% through March 31, 2023.  Comprehensive Regulatory Telehealth Reform  Proposes expanding access to telehealth services across the state by amending the Public Health, Education, and Insurance laws.  Individuals may receive telehealth services wherever they are located, subject to Federal approval. Health information would be exchanged via the Statewide Health Information Network (SHIN-NY) through the use of a single statewide consent. Creation of an interstate licensure program with contiguous states and states in the Northeast region would support telehealth for specialties with historical provider access issues. Workforce Education Programs Amends the Education Law to streamline the current approval process for new curriculum or education programs of study at an accredited college or university chartered in New York State in order to respond quickly to ever-changing needs of employers for workforce. Proposed programs that do not lead to professional licensure must meet all of the application criteria at an accredited college or university. Eliminate e-Prescribe Exemptions: Amends the Public Health Law and Education Law to eliminate prescriber exemptions to the mandatory electronic prescribing requirement except for emergency situations. This proposal would amend Public Health Law to eliminate exceptions for prescribing including those veterinarians and practitioners who have received exemptions from e-Prescribing. Remaining exceptions include temporary technological or electrical failure and emergency situations determined by the commissioner. The effective date would be November 1, 2021. Paid Leave for COVID-19 Vaccination This proposal would require public and private employers to provide up to four hours of paid leave, at the employee’s regular rate of pay, for up to two COVID-19 vaccinations for each employee. An employer that provides or arranges to provide a COVID-19 vaccination at the employee’s workplace would need only to provide sufficient time for an employee to obtain the vaccine. Employers would be prohibited from taking retaliatory actions against any employee who would utilize this leave but may request relevant documentation from an employee. Capital Improvements Financing  Extends the authorization related to the financing of certain health care improvements through March 31, 2023. ASSISTED LIVING  Federal Supplemental Security Income Cost of Living Adjustment  Amends the Social Services Law for an individual receiving Congregate Care Level 3 to an $11 per month increase (from $1,477 to $1,488). For eligible couples receiving Congregate Care Level 3 a $22 per month increase (from $2,954 to $2,976) was given. This also increased Personal Needs Allowance (PNA) for each individual in Congregate Care Level 3 by $3 per month (from $207 to $210), an increase of 1.4 percent.  Eliminate Requirement to Administer an Adult Home Advocacy Program within the Justice Center Eliminates the requirement of the Justice Center for the Protection of People with Special Needs (Justice Center) to administer the Adult Home Advocacy and Adult Home Resident Council Programs. EQUAL Funding & Enriched Housing Subsidy Program Proposes to discontinue support for the Enhanced Quality of Adult Living (“EQUAL”) and the Enriched Housing Subsidy Program, effective April 1, 2021. Authorization and Implementation of Medical Respite Pilot Program Allows for the creation of a not-for-profit corporation to become an operator of a medical respite program to provide care to a vulnerable population, by offering medical respite programs as a lower intensity care setting for individuals who would otherwise require a hospital stay or lack a safe option for discharge and recovery. Medical respite programs will reduce hospital inpatient admissions by providing temporary room and board and the provision or arrangement of the provision of healthcare and support services. NYSHFA|NYSCAL will continue to provide regular updates as the FY 2021-22 Budget negotiations progress. NYSHFA/NYSCAL CONTACTS: Stephen B. Hanse, Esq. President & CEO 518-462-4800 x11 Read More

Governor Cuomo's 2021 State of the State Address

Governor Andrew M. Cuomo presented his 2021 State of the State address today with the theme of “Reimagine, Rebuild, Renew.” The Governor used his 2021 State of the State address to provide an overview of seven policy area initiatives. The Governor announced that in the coming days he will follow up these initiatives with three additional presentations to further set forth the proposed action plans that will be included within the seven initiatives. Read More
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