Objective

To determine whether the Office of Addiction Services and Supports (OASAS) offers adequate guidance to providers to help ensure they’re able to deliver addiction support services during emergency situations. Our audit covered the period from January 2019 through November 2022.

About the Program

OASAS’ mission is to improve the lives of New Yorkers by leading a comprehensive system of addiction services for prevention, treatment, and recovery. OASAS operates 12 Addiction Treatment Centers and oversees nearly 400 providers that it has certified to operate more than 1,000 substance use disorder and problem gambling treatment and prevention programs (Programs) across the State. These Programs serve an average of 100,000 individuals on any given day. To open and operate a new Program, providers must apply for and obtain OASAS certification. Programs may be certified to operate for a 6-month or 1-, 2-, or 3-year period before recertification.

OASAS issues Local Service Bulletins (LSBs) that provide guidance to addiction service providers and may include administrative directives that providers must follow. OASAS’ certified treatment providers are required by certain LSBs to have Emergency Preparedness Plans (Plans) and to re-evaluate and revise them following an incident such as a major fire or flood, disease outbreak, or terrorist attack. These LSBs state that OASAS personnel will review provider Plans at both recertification site visits and visits from the Regional Office. Providers are also required to be set up to use the New York State Evacuation of Facilities in Disasters System (eFINDS), an application that allows them to monitor where a patient is evacuated from and moved to. To use eFINDS, each Program must have at least one assigned Coordinator and one assigned User. In addition, in some circumstances providers must maintain a list of applicants awaiting treatment and report this information in the OASAS Client Data system. OASAS established a Waiting List Report to measure the need for additional treatment capacity and to manage access to treatment. Waiting list information can also be used by OASAS to inform discussions regarding gaps in care and capacity.

Key Findings

Although OASAS provides guidance to help providers ensure they’re able to deliver addiction support services during emergency situations, such as fires or evacuations, OASAS should improve upon the extent and clarity of this guidance.

Given the disruptions that accompanied the COVID-19 pandemic, OASAS should also improve its monitoring to better ensure that provider Plans are revised when warranted and that they include strategies to manage and mitigate prolonged disruptions in service to prevent the related loss of progress and momentum.

Further, OASAS should do more to gain assurance that certain tools that providers use – such as eFINDS and waiting lists – are in place and suitable to use for managing services to their clients. The weaknesses we identified indicate that Programs may not be adequately prepared for emergency situations, which could compromise safety and continuity of care.

Specifically, we found that:

• OASAS personnel review Plans only at initial certification, despite guidance that states they will review them at later site visits.
• Some OASAS-certified Programs are not set up to be able to use eFINDS and would likely be unable to access it in the event of an emergency. This increases the risk of losing track of patient movement and transfer locations and may compromise continuity of care.
• Although OASAS uses a central repository for waiting list information, some providers may not be entering required information, and the information that OASAS does receive may not be accurate or entered timely. Further, OASAS doesn’t make efforts to improve the accuracy of this information and its usefulness for decision making.

Key Recommendations

• Review and revise the LSBs, site review instruments, and any other guidance, as considered necessary, to:
  • Incorporate provisions that address providers’ plans to manage and mitigate prolonged disruptions in service.
  • Clearly describe the responsibilities of both providers and OASAS personnel related to Plans, eFINDS readiness, and waiting list requirements.
• Implement a risk-based method to:
  • Review Plans subsequent to the initial certification.
  • Verify provider access to eFINDS, including verification that assignments to key roles are current.
• Improve the use of waiting list information submitted by providers to better support OASAS’ decision making and oversight.