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State of New York Office of the State Comptroller Division of Management Audit

OFFICE OF MENTAL RETARDATION AND DEVELOPMENTAL DISABILITIES FAMILY CARE PROGRAM

REPORT 95-S-139

H. Carl McCall

Comptroller

State of New York Office of the State Comptroller

Division of Management Audit Report 95-S-139

Mr. Thomas A. Maul Commissioner Office of Mental Retardation and Developmental Disabilities 44 Holland Avenue Albany, NY 12237-0001 Dear Mr. Maul: The following is our audit report on the Office of Mental Retardation and Developmental Disabilities' family care program. This audit was performed pursuant to the State Comptroller's authority as set forth in Section 1, Article V of the State Constitution and Section 8, Article 2 of the State Finance Law. Major contributors to this report are listed in Appendix A.

November 14, 1996

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Executive Summary Office Of Mental Retardation And Developmental Disabilities Family Care Program

Scope of Audit

In the family care program, the Office of Mental Retardation and Developmental Disabilities (OMRDD) oversees care provided to disabled individuals who do not require the intensive level of care provided by OMRDD's developmental centers. The primary care is provided by non-family members in private homes, where the disabled individuals live. Therapy and other specialized care (called day programming) are provided by contractors and OMRDD staff at other sites. About 2,400 providers care for about 4,600 disabled individuals in family care homes. During the 1995-96 fiscal year, OMRDD was budgeted about $23.4 million for the family care program. Our audit addressed the following questions about OMRDD's administration of the family care program for the period April 1, 1994 through February 29, 1996: ! ! ! ! Does OMRDD adequately monitor the care given to the disabled individuals in the program? Does OMRDD adequately screen prospective family care providers? Does OMRDD adequately train the providers? Does OMRDD adequately administer loans that are given to providers to enable them to either acquire new homes or improve their existing homes to meet the standards of the family care program?

Audit Observations and Conclusions

We identified a number of opportunities for improvement in OMRDD's administration of the family care program. Improvements can be made in the procedures used to monitor program care, screen providers, train providers, and administer loans to providers. To ensure that the care provided by the family care program is appropriate, family care homes and day programming sites are to be visited periodically by either OMRDD staff or staff from certain not-for-profit organizations. However, we found that, in some cases, these visits were not made as often as required. In one case, as much as 11 months passed between visits. We also identified variations in the procedures used in making these visits. We made

recommendations that could improve both the effectiveness and efficiency of the procedures used to monitor the family care program. (See pp. 5-7) Family care providers must be certified by OMRDD, and certification cannot be given to anyone who has been convicted of a felony. However, we found OMRDD does not check the criminal histories of prospective family care providers. In addition, since April 1992, OMRDD has screened prospective providers against a registry of alleged child abusers; however, the providers who were certified before April 1992 have not been checked against the registry. We recommend OMRDD ensure that all active providers have been screened for felony convictions and child abuse. (See pp. 9-10) OMRDD requires family care providers to attend a basic training program either prior to, or within six months of, their initial certification. However, we found that persons who temporarily substitute for regular providers are not required to receive this training. If these temporary respite providers and sitters are not adequately trained, the well-being of the disabled individuals in their care may not be adequately protected. We recommend that respite providers and sitters receive appropriate training. (See pp. 10-11) To encourage providers to participate in the family care program, OMRDD may lend providers up to $20,000 to enable them to either acquire new homes or improve their existing homes to meet program standards. Between 1992 and 1995, 89 of these loans were awarded totaling $1.1 million. The loans are interest free and need not be repaid if the provider remains in the program for a certain amount of time. We identified several weaknesses in OMRDD's administration of these loans. For example, improvements were not always verified by OMRDD and additional program capacity may not have always been needed. Further, most of the loans since 1992 were made to current and former employees of OMRDD, which could give the appearance of favoritism. According to OMRDD officials, these employees received loans because they were willing to care for the highly disabled individuals who were displaced by the closing of certain developmental centers. We acknowledge that family care homes had to be found for these individuals, but note that OMRDD did not formally disclose that loans were more likely to be awarded to providers who were willing to accept such individuals. We recommend that loan award criteria be fully disclosed. (See pp. 13-17 )

Comments of OMRDD Officials

OMRDD officials agree with our recommendations and advised us of the actions they have either taken or plan to take to implement them.

Contents

Introduction

Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 Audit Scope, Objectives and Methodology . . . . . . . . . . . . . . . . . . . . . 2 Response of OMRDD Officials to Audit . . . . . . . . . . . . . . . . . . . . . . . 3

Oversight of Family Care Homes Provider Screening and Training Loans to Providers

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Provider Screening . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Provider Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

Loan Administration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 Loans to Employees . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

Appendix A

Major Contributors to This Report

Appendix B

Comments of OMRDD Officials

Introduction

Background

The Office of Mental Retardation and Developmental Disabilities (OMRDD) provides services to more than 84,000 developmentally disabled individuals. OMRDD has moved away from a system in which these individuals were served primarily in large institutions to a system in which they are served primarily in the community. This community-based system provides individualized care in various residential, medical and training programs that offer more choice to the disabled individuals and their families. In its family care program, OMRDD oversees care provided to disabled children, adolescents and adults who do not require the intensive level of care provided by OMRDD's developmental centers. The family care program represents one of OMRDD's least restrictive and most independent living arrangements for disabled individuals. It provides a structured and stable home environment, and creates an atmosphere of family living. The primary care is provided by non-family members in private homes, where the disabled individuals live. Therapy and other specialized care (called day programming) are provided by contractors and OMRDD staff at other sites. The family care program, which was established in 1931, is one of New York's oldest community-based residential programs for disabled individuals. Since 1977, the homes used in the program have been limited by regulation to six disabled individuals. The typical family care home has one or two disabled individuals. In total, approximately 2,400 providers serve about 4,600 disabled individuals in family care homes. Both the homes and the providers must be certified by OMRDD. To ensure that the care provided in the family care program is appropriate, OMRDD monitors the care given to the disabled individuals in the program, screens prospective providers, and trains the providers accepted into the program. To encourage people to participate in the program as family care providers, OMRDD makes loans to providers to enable them to either acquire new homes or improve their existing homes to meet program standards. OMRDD supervises the family care program through its 13 regional District Developmental Service Offices (DDSOs). In addition, about 325 family care providers are also supervised by not-for-profit organizations called voluntary agencies. As the family care program has expanded, OMRDD has sought to make greater use of these voluntary agencies in helping to supervise the family care program. To feed and house the disabled individuals in their care, family care providers receive a monthly Supplemental Security Income stipend from the U.S. Social

Security Administration, as well as additional funds from OMRDD. During the 1995-96 fiscal year, OMRDD was budgeted about $23.4 million for these and other costs incurred in administering the family care program.

Audit Scope, Objectives and Methodology

We audited selected aspects of the family care program for the period April 1, 1994 through February 29, 1996. The objectives of our audit were to assess the adequacy of the procedures used by OMRDD to monitor the care given to the individuals in the program, screen prospective family care providers, train providers participating in the program, and administer loans to providers. To accomplish our audit objectives, we examined the policies and procedures governing the family care program. We also reviewed records and interviewed officials at the OMRDD central office, three DDSOs and four voluntary agencies. Our audit was performed according to generally accepted government auditing standards. Such standards require that we plan and perform our audit to adequately assess those operations of OMRDD which are included within the audit scope. Further, these standards require that we understand OMRDD's internal control structure and its compliance with those laws, rules and regulations that are relevant to OMRDD's operations which are included in our audit scope. An audit includes examining, on a test basis, evidence supporting transactions recorded in the accounting and operating records and applying such other audit procedures as we consider necessary in the circumstances. An audit also includes assessing the estimates, judgments and decisions made by management. We believe that our audit provides a reasonable basis for our findings, conclusions and recommendations. We use a risk-based approach to select activities for audit. We therefore focus our audit efforts on those activities we have identified through a preliminary survey as having the greatest probability for needing improvement. Consequently, by design, we use finite audit resources to identify where and how improvements can be made. We devote little audit effort to reviewing operations that may be relatively efficient and effective. As a result, we prepare our audit reports on "an exception basis." This audit report, therefore, highlights those areas needing improvement and does not address those activities that may be functioning properly.

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Response of OMRDD Officials to Audit

A draft of this report was provided to OMRDD officials for their review and comment. Their comments have been considered in preparing this report and are included as Appendix B. Within 90 days after final release of this report, as required by Section 170 of the Executive Law, the Commissioner of the Office of Mental Retardation and Developmental Disabilities shall report to the Governor, the State Comptroller, and the leaders of the Legislature and fiscal committees, advising what steps were taken to implement the recommendations contained herein, and where recommendations were not implemented, the reasons therefor.

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Oversight of Family Care Homes

According to OMRDD regulations, to ensure that the care provided by the family care program is appropriate, family care homes and day programming sites must be visited periodically by staff from the DDSOs or staff from the voluntary agencies. However, we found that, in some cases, these visits were not made as often as required. We also identified variations in the procedures used in making these visits. According to OMRDD regulations, each disabled individual in the family care program must be visited at least monthly by either DDSO staff or staff from the supervising voluntary agency. Further, at least once each quarter, this visit must take place at the day programming site. OMRDD regulations also require that each family care home be visited at least monthly, with at least one visit per year conducted on an unannounced basis. The purpose of these visits is to ensure that the care provided is appropriate. A record of the visits must be maintained by either the DDSO or the voluntary agency, depending on who made the visit. To determine whether these visits were made as often as required, we reviewed the visits that were made over a one-year period in relation to 81 disabled individuals who lived at 87 different family care homes during the period. The individuals and homes were overseen by three DDSOs (Capital District, Syracuse and Bernard Fineson), and some of the individuals and homes were also overseen by four voluntary agencies (Montgomery ARC, Little Flower, Enable Inc., and Homes Inc.). The 81 individuals were selected by us in a judgmental sample. According to the records maintained by the DDSOs and voluntary agencies, more than half of the individuals and homes were not visited as often as required, as follows:

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Type of Visit - Frequency Individual - Monthly Day Program - Quarterly Home - Monthly Unannounced - Annual

Individuals or Homes Visited 81 81 87 51 [a]

At Least One Visit Missed 47 64 51 26

Percent With Missed Visits 58% 79% 59% 51%

[a] 36 of the 87 homes in our sample were overseen by the Syracuse DDSO, whose records did not indicate whether a visit was announced or unannounced. Therefore, we could not determine whether unannounced visits were conducted at these 36 homes.

If the individuals and homes in the family care program are not visited as required, OMRDD officials have less assurance that the care provided by the program is appropriate. We note that some DDSOs and voluntary agencies were better at making the required visits than others. For example, the Capital District DDSO made virtually all of its required visits and the Montgomery ARC made more than its required number of visits. In contrast, the Bernard Fineson and Syracuse DDSOs missed many visits. In fact, one of the individuals and homes overseen by these DDSOs was not visited for as long as 11 months, while another was not visited for nine months. Officials at the Bernard Fineson DDSO told us that they were unable to make a number of visits because of case manager vacancies. This DDSO oversees many disabled individuals who are covered by the Willowbrook Consent Decree, and the Decree limits the number of individuals who can be assigned to any case manager. Therefore, DDSO officials could not temporarily increase the caseloads of its case managers to compensate for the vacancies. While the officials acted quickly to hire new case managers, some disabled individuals were not assigned a case manager for extended periods. If similar situations occur in the future, OMRDD needs to ensure that disabled individuals are not unsupervised for months at a time, even if they are visited less frequently than required. Officials at the Syracuse DDSO told us that they do not visit certain providers as often as required because the providers are highly qualified and reliable, and therefore need less supervision. For example, one such provider is a neonatal intensive care nurse and another is a special education teacher. The officials

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told us that, by making fewer visits to these providers and the individuals in their care, they are able to devote more attention to less skilled providers who need more assistance. While this may be a reasonable approach to efficiently using existing resources, it is not consistent with the regulations governing the family care program. OMRDD officials therefore need to evaluate whether the regulations should be modified. We also noted that the Bernard Fineson and Syracuse DDSOs assign a single staff to oversee both the homes and the individuals in the family care program, while the Capital District DDSO assigns one staff to oversee the homes and another staff to oversee the disabled individuals in the program. We recognize that the use of a single staff for monitoring may be more efficient. At the same time, independent reviews by two individuals can provide better assurance that the care in the program is appropriate. We recommend that OMRDD determine which approach is best and ensure that the best approach is used throughout the family care program.

Recommendations

1. Ensure that individuals and homes in the family care program are visited in accordance with OMRDD regulations. Evaluate whether the regulations should be modified to require fewer visits when providers are more skilled. Develop procedures to prevent individuals and homes from being unsupervised for long periods of time. Determine whether one or two staff should be used by DDSOs to monitor the homes and individuals in the family care program.

2.

3.

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Provider Screening and Training

OMRDD is responsible for ensuring that the individuals placed in family care homes are cared for by persons of good moral character who possess the appropriate skills and training. We examined the procedures used by OMRDD to screen and train family care providers. We found that OMRDD has a basic training program for providers; however, the persons who temporarily substitute for regular providers are not required to receive this training. We also found that improvements are needed in OMRDD's procedures for screening prospective providers.

Provider Screening

A person may become a family care provider only after receiving an operating certificate from OMRDD. Applications for a certificate are made in writing through the appropriate DDSO, which is responsible for evaluating and verifying the applicant's background, as well as other information provided on the application. This information generally includes the applicant's work experience, education history, and other relevant skills or completed training courses; at least three references unrelated to the applicant; and any misdemeanors or felonies committed by the applicant. Once certified, providers must be recertified every two to three years. According to OMRDD regulations, a family care operating certificate cannot be awarded to anyone who has been convicted of a felony. However, we determined that none of the 13 DDSOs has a procedure in place to check the criminal histories of applicants seeking either certification or recertification. As a result, applicants who fail to disclose convictions may be awarded an operating certificate and may jeopardize the well-being of the disabled individuals in their care. The Department of Social Services maintains a Child Abuse Registry, which includes the names of alleged child abusers. Since April 1992, the DDSOs have compared the names of all new providers to the names in the Registry. We believe this procedure helps protect the well-being of disabled individuals in family care homes. However, this protection has not been provided to disabled individuals in family care homes that were certified before April 1992. OMRDD officials could not tell us when the 2,400 active family care providers were first certified. As a result, we could not determine how many of the providers have never been checked against the Registry. According to OMRDD records, more than 3,400 providers were first certified before 1992 and more than 1,900 providers have been initially certified since January 1992. We also note that providers are not checked against the Child Abuse Registry when they are recertified. We believe such a check would provide additional protection for the disabled individuals in the family care program.

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Beginning in September 1995, the DDSOs were required by OMRDD guidelines to expand their review and compare the names of all adults living in the family care homes to the names in the Child Abuse Registry. We believe this procedure also helps protect the well-being of disabled individuals in family care homes, but again note that this protection has not been provided to disabled individuals in family care homes that were certified before September 1995. We also found that, contrary to OMRDD guidelines, one DDSO had not expanded its review to compare the names of all adult members in family care homes to the names in the Child Abuse Registry.

Recommendations

4. Pursue means to verify the criminal histories of prospective providers seeking certification and of providers seeking recertification. Ensure that all providers and other adults living in family care homes have been checked against the Child Abuse Registry.

5.

Provider Training

Family care providers must be trained to ensure that they have the skills necessary to care for disabled individuals. Accordingly, OMRDD requires the providers to attend a 20-hour training program either prior to, or within six months of, their initial certification. This training program covers such topics as provider and DDSO responsibilities, reportable incidents and abuse, environmental standards, the operation and certification of family care homes, the protection of individuals receiving services, and safety and security procedures. Thereafter, any training updates or specialized instruction is provided informally as needed. We found that, while all regular providers are required to attend the 20-hour training program, persons who temporarily substitute for the regular providers are not required to attend the program. For example, OMRDD allows each provider to take up to 14 days of leave from their responsibilities each year. During such leave, the disabled individuals are cared for by respite providers. Respite services are available whenever the provider is absent from the home or in need of relief for a short period of time. Respite services may be provided in the family care home, in the home of an approved respite provider, in an OMRDD community residence, or in an approved freestanding respite site. Sometimes, respite services are provided by other family care providers. Despite the frequent use of respite providers, such providers are not required to attend an appropriate training program.

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OMRDD also allows family care providers to use sitters for up to 15 hours a week. Sitters may be used when the disabled individual returns home from scheduled day programming activities before the provider returns home from work, or when the disabled individual cannot attend the scheduled activities and the provider cannot be at home. Despite the frequent use of sitters, they are also not required to attend an appropriate training program. OMRDD officials do not require respite providers and sitters to be trained because the officials consider the regular providers to be principally responsible for the well-being of the disabled individuals in the family care program. We acknowledge that the regular providers are principally responsible for providing care, but note that a significant amount of care is also provided by respite providers and sitters. If respite providers and sitters are not adequately trained, the well-being of the disabled individuals in their care may not be adequately protected.

Recommendation

6. Require sitters and respite providers to attend an appropriate training program.

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Loans to Providers

To encourage people to become providers in the family care program, OMRDD makes loans to providers to enable them to either acquire new homes or improve their existing homes to meet program standards. OMRDD makes three different types of loans, as follows: ! Down payment/renovation loans of up to $20,000 are available for the purchase of new family care homes or to bring existing homes into compliance with certification standards. Environmental modification loans in amounts up to $20,000 are available to certain providers to finance structural changes, such as wheelchair ramps and lift systems, that are required to make the home more accessible or functional for the disabled individuals in the homes. Lease loans of up to $5,000 are available to providers who wish to rent a residence. These loans generally cover up-front lease costs such as security deposits and advance rental payments. The loans are available to providers entering the program, as well as existing providers who want to increase their certified capacity.

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!

Nine DDSOs reported awarding 89 loans between 1992 and 1995 totaling $1.1 million. The loans are interest free and need not be repaid if the providers remain in the program long enough: loans for the maximum amount of $20,000 are forgiven after six years, while loans for lesser amounts are forgiven sooner. These provisions apply even if a disabled individual is not placed in the home. We identified several weaknesses in OMRDD's administration of loans to family care providers. We also noted that many loans were made to current and former employees of OMRDD. While many OMRDD employees serve as family care providers and are therefore eligible for such loans, the manner in which some of the loans were made could create the appearance of favoritism.

Loan Administration

The OMRDD central office maintains records relating to loans to family care providers. We examined these records for the 89 loans made between 1992 and 1995. We found that the records were significantly incomplete, as 69 of these loans were not even listed in the central office records. A total of 41 of the unrecorded loans were for less than $10,000, and OMRDD officials told us that such loans are not recorded by the central office; the officials could not explain why the remaining 28 loans were not recorded. In the absence of adequate records, the OMRDD central office cannot adequately oversee the

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loans made to family care providers. We note that these recordkeeping weaknesses were previously noted by an OMRDD work group in May 1995. At any given time, a family care home may not have any disabled individuals in the home. For example, between April 1994 and December 1995, between 63 and 120 certified homes were empty each month in the Syracuse and Capital District DDSOs. Despite the availability of so many empty homes in these areas, between June 1993 and December 1995, these two DDSOs approved 22 down payment/renovation loans. Such loans can expand the capacity of existing family care homes. We question whether additional capacity was needed at this time, and note that the records maintained by the OMRDD central office do not indicate the capacity of the family care program in each DDSO. In the absence of such records, it is difficult for the managers who approve loans to determine whether additional capacity is needed. OMRDD officials expressed confidence that the additional capacity created by the 22 loans was necessary to the family care program. The officials at the Syracuse DDSO told us that many certified family care homes are maintained simply for use as respite homes, and some providers are willing to accept individuals only if their disability levels are very low. We acknowledge that some homes must be kept empty for these reasons, but note that the records maintained by OMRDD do not indicate why homes are empty. Without this information, the true capacity of the family care system cannot be determined and the need for new capacity cannot be adequately evaluated. The loans to the providers are to be administered in accordance with guidelines developed by OMRDD. We examined the administration of the loans and found that the guidelines were not always followed. As a result, there is an increased risk that loan funds can be used inappropriately. For example: ! When loans are made for renovation work, the completed work should be verified by DDSO staff. Six such loans were made by the Syracuse DDSO. However, in five of these loans, there was no indication in the loan files that the completed work was reviewed by DDSO staff. As a result, OMRDD has less assurance that the funds were used as intended. When loans are made for renovation work, the provider should obtain three bids to do the work. However, the file for one renovation loan contained no indication that any bids had been obtained. In addition, the loan totaled $2,200, even though the provider requested only $1,500. A down payment/renovation loan should not exceed $20,000. However, in December 1995, a provider received a down payment/renovation loan of $27,350.

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To encourage providers to participate in the family care program, the loans made by OMRDD are interest free and are forgiven if the provider remains in the program long enough. Therefore, if a provider leaves the program before the loan has been forgiven, it is reasonable to expect that interest would be accrued against any unpaid loan balance. We found, however, that loans continue to be interest free even when providers leave the program before their loans are forgiven. We identified four such ex-providers whose original loans totaled $34,560. At the time of our audit, two of these ex-providers were four months behind in their payments, and the interest-free repayment period of one of these ex-providers had already been extended by 30 months. To secure the State's interest in property that was purchased or improved through loans to family care providers, the standard loan agreement with the providers should assert OMRDD's interest in the property and OMRDD should file liens against such property. However, we found that the standard loan agreement does not sufficiently protect OMRDD's interest in the property and OMRDD does not file liens against such property. As a result, should a provider decide to leave the program or sell the property, OMRDD is at greater risk of losing its interest in the property.

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Recommendations

7. Establish a complete and detailed centralized recordkeeping system for the loans made to family care providers. Establish a complete and detailed recordkeeping system describing the occupancy and the capacity of the family care program in each DDSO, and ensure that this information is considered when loans are evaluated. Ensure that loans to providers are administered in accordance with OMRDD guidelines. Modify the standard provider loan agreement to include a provision for interest charges on unpaid balances in the event a provider leaves the family care program prematurely. Modify the standard provider loan agreement to include a provision giving OMRDD a security interest in the improved or purchased property. Ensure that appropriate property liens are filed.

8.

9.

10.

11.

Loans to Employees

In recent years, OMRDD has closed several of its large developmental centers. Some of the displaced developmental center staff have become family care providers. In total, current and former OMRDD employees represent almost 15 percent of all family care providers. OMRDD officials recognize that the accumulated training and experience of current and former employees are assets to the family care program, but there are no provisions to target loan funds to such providers. Yet, we found that about 53 percent of the monies lent to providers between 1992 and 1995 went to current or former employees. The Capital District and Syracuse DDSOs, which were particularly affected by the recent facility closures, have accounted for 64 (72 percent) of the 89 provider loans granted since 1992. Officials from the Syracuse and Capital District DDSOs told us that loans were targeted to providers who would accept individuals with higher disability levels, because the placement of such individuals facilitated the closure of the developmental centers. According to OMRDD records, almost all of the loans in the Capital District DDSO between 1992 and 1995 were made to providers who accepted individuals directly from either developmental centers or community residences (such individuals tend to have higher disability levels), and the loans in the Syracuse DDSO during this period were made to providers

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who accepted individuals with higher disability levels. OMRDD officials told us that providers willing to accept individuals with higher disability levels tend to be current or former employees. We recognize the difficulties involved in closing large institutions and transferring residents to community settings, particularly residents who are highly disabled. However, OMRDD did not formally disclose that such providers would receive preference in receiving loans. As a result, we are concerned that all loan applicants may not have been aware of this preference and therefore may not have had an equal opportunity to compete for funding. Moreover, when the criteria for awarding the loans are not clearly and fully disclosed, it is easy for the large number of loans awarded to current and former employees to be perceived as favoritism, especially when OMRDD staff continue to face layoffs from downsizing. We discussed this issue with central office officials, who indicated they were unaware that so many of the loans were awarded to current and former employees. The officials acknowledge the need to ensure that the loans do not appear to be targeted to employees.

Recommendation

12. Clearly and fully disclose the criteria for awarding loans to providers.

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Major Contributors to This Report

Jerry Barber David DeStefano Frank Houston Kevin McClune Ken Spitzer John F. Buyce Todd Seeberger Michael Filippone Michelle Privor Robert Russell Michael Wright Dana Newhouse

Appendix A

Appendix B

B 2 -2

B-3

* Note

B 4 -4

*See State Comptroller's Note, Appendix B-8

B-5

B 6 -6

B-7

State Comptroller's Note Recommendation 6 in the draft report was revised in the final report.

B 8 -8

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