Call us at 888.368.2463    CONTACT US
 Back to Blog

Penalties for Late Consolidated Fiscal Reports

Do you receive payments from the New York State Office for People With Developmental Disabilities (OPWDD), Medicaid payments from the NYS Office of Mental Health (OMH), or the NYS Office of Alcoholism and Substance Abuse Services (OASAS)?

If so, you’ll want to investigate late filing penalties association with Consolidated Fiscal Reports (CFR).

 

In the November MP&S Nonprofit Alert from Marks Paneth & Shron, the following was reported:

 

The New York State Office for People With Developmental Disabilities (OPWDD) is planning to implement a 2% penalty for late submission of the Consolidated Fiscal Report (CFR).  A not-for-profit service provider’s reimbursement will be cut by 2% and the rate will be restored only upon submission of the CFR.  There will be no refund on the money lost during the overdue period.

According to the New York State Consolidated Fiscal Reporting and Claiming Manual, all service providers must submit their completed CFR to the applicable State funding agencies not later than 120 days after the end of the reporting period.  If an extension is submitted, the due date is not later than 150 days after the end of the reporting period.  An extension request must be electronically submitted.  For example, a June 30, 2011 CFR, with an extension is due on December 1, 2011.  Late submissions of a CFR, including all certifications and attachments, may result in a sanction or penalty being imposed against the service provider.

Providers who receive Medicaid payments from the NYS Office of Mental Health (OMH) relative to certified program services can have their payments temporarily withheld up to 20% for the first month under sanction.  Such reductions will be increased in each subsequent month by 10% until the CFR is submitted.  Providers who receive payments under contract with OMH can have their entire quarterly payments withheld until a satisfactory submission has been received.

Similarly, the NYS Office of Alcoholism and Substance Abuse Services (OASAS) can impose sanctions for late filing of the CFR as prescribed in OASAS Local Services Bulletin 2001-05.

The current regulations allow OPWDD to withhold up to 5%

of the revenue in certain programs; however, it was not strictly enforced.  Now OPWDD is planning to impose a sanction of 2% on all programs.  Originally, OPWDD planned to implement a 10% cash hold-back policy on all programs but that proposal was rejected.

Related Posts:
Reap the Benefits of Your Hard Work: Practical Strategies for Using Impact Data
June 29, 2018
Reap the Benefits of Your Hard Work: Practical Strategies for Using Impact Data

Can you imagine spending months tending to your garden, only to let the vegetables you’ve been growing rot before anyone can enjoy them? Hardly. Yet when it comes to data collection and use, many organizations do just that. They toil away setting up plans to deliver services and track results. They pour sweat and tears…

Why Every Nonprofit Needs Dashboards to Resolve the Visibility Issue
March 23, 2017
Why Every Nonprofit Needs Dashboards to Resolve the Visibility Issue

As a CFO of a nonprofit, you not only face unique challenges in business and finance but also experience significant pressure to prove you’re making the right decisions about your organization. Board members and stakeholders expect to see you’re making informed and successful decisions about your organization’s financial matters. More than ever, donors want transparency…

Skating The Edge Between Risk and Reward at Your Nonprofit
March 5, 2019
Skating The Edge Between Risk and Reward at Your Nonprofit

Every nonprofit faces risk, but it doesn’t have to be a liability. Learn to take a holistic view of risk and use the unexpected to your advantage. What if your funding was cut by half overnight? It might sound impossible, but given the precarious financial situation most nonprofits face, it’s a very real risk. You…

7 Steps to Nonprofit Risk Management
May 21, 2018
7 Steps to Nonprofit Risk Management

Nonprofits face risk on all sides. In a March 2016 report, Oliver Wyman and SeaChange Capital Partners list some of the difficult conditions under which nonprofits must operate. Among these are: Tackling society’s hardest problems Limited funding Increasing costs for services Recruiting and retention Ever-changing operating environment These experts conclude, “It is no surprise that…

 Back to Blog