American Rescue Plan Act (ARPA) Supplemental Guidance For Adult Day Health Care And Aids Adult Day Health Care Programs (ADHCs AND AADHCs)

• Guidance is also available in Portable Document Format (PDF)

APRIL 2025 UPDATE

Below are some updates, reminders and additional guidance about this funding. The following is based on questions received and issues encountered during the first two reporting periods.

Introduction

The ARPA grant is one-time funding to support activities to strengthen workforce stability, service support, and emergency preparedness in ADHCs that are providing services to Medicaid residents. Below are some updates, reminders, and additional guidance. This update outlines the roles and responsibilities of awarded sites. It supplements guidance released earlier and found here: ARPA ADHC Guidance.

Contacts

It is important to inform the DOH ARPA team of any contact changes as soon as possible. This will ensure all ARPA communications are sent to the correct individuals as timely as possible. Contact changes or updates can be sent to our mailbox at: ADHC_ARPA@health.ny.gov.

Spending Plans

Programs may need to redistribute funding amounts or revise the timeline on their spending plans, however, there is no need to submit these changes to the ARPA team for review or approval. Updated spending plans need to be submitted as part of your quarterly reporting documentation. Reminder: Funding must be spent in accordance with ARPA guidelines.

Extensions

As noted in previous guidance, extension requests were due by February 1st, 2025. Determinations have been made and sent to applicable settings. No additional spending extensions will be given, so please continue to prioritize any remaining spending accordingly. If you need assistance or have questions, please contact the ARPA team at: ADHC_ARPA@health.ny.gov.

Quarterly Reporting

The table below shows the remaining ARPA reporting requirements and relevant dates. We will continue to use the Alchemer platform for these reporting requirements. Please

remember that all programs should complete a quarterly survey, even if no award funds were spent during the reporting period. Programs must complete quarterly reporting and provide proof of spending to retain their awards and maintain eligibility for future enhanced funding opportunities.When the link to the Quarter 2 survey was sent via email on January 15th, 2025, some emails were sent to junk or spam folders, so please remember to check junk or spam folders.

REMAINING ARPA QUARTERLY REPORTING REQUIREMENTS
Survey	Spend-Down/Reporting Period	Survey Release Date	Survey Due Date
Quarter 3	January 1, 2025 – March 31, 2025	April 15, 2025	May 6, 2025
Quarter 4	April 1, 2025 – July 31, 2025	August 15, 2025	September 5, 2025
Approved Extensions Only*	July 31, 2025 – Through previously approved extension date	October 1, 2025	October 15, 2025

*If you did not receive approval upon applying for an extension prior to February 1st, 2025, this does not apply to you. There will be no new extensions and those without extensions must expend all funds by July 31, 2025.

Required Documentation

All spending must be supported by submitting proof of payment. As materials are submitted and reviewed by the DOH ARPA Team. The Team will reach out when documentation is missing, figures do not equal the reported amount spent or spending does not align with the ARPA guidelines.

When submitting ARPA investment documentation and proof of payment, please remember:

1. All attachments (PDFs, Word and Excel documents, receipts etc.) should be given a file name that describes its purpose.
2. An unpaid invoice is not acceptable without proof of payment.
3. Acceptable proofs of payment include copies of checks, paystubs, and credit card receipts/statements.
4. Documentation should reflect only spending that occurred in the reporting period.
5. On attachments showing proof of payment, please circle the payment amount on each page. If submitting multiple pages regarding the same expenditure, such as an invoice, a purchase order and a copy of a check, only circle the amount once on the actual payment page.
6. The total of the amounts circled on all pages must equal the total reported for the quarter. If this is not the case a revision will be requested.
7. For employee bonuses, please submit copies of checks or a full payroll report. Submission must include the employee's name, title, and amount claimed. Spreadsheets may be helpful for organization but are not acceptable for verification. If claiming payroll taxes, please circle that amount as well.
8. If a contract is submitted, it must be signed by all parties and reflect the relevant contracting period (the contracting period should be within the ARPA funding period of July 2024 to July 2025).
9. If training is provided, in addition to a signed contract and proof of payment, training materials and proof of training completion should be submitted.
10. All documentation of spending will be reviewed for compliance and must be retained by your program until July 31st, 2033.

Below are some examples of ARPA investments and the acceptable supporting documentation and required proof of payment documentation that should be submitted to the Department.

ACCEPTABLE FORMS OF ARPA SPENDING DOCUMENTATION
Investment Example	Supporting Documentation	Valid Proof of Spending
Staff Bonuses	Bonus announcement	Individual record of bonuses paid out to staff, such as a copy of a paycheck or paystub
Job Postings	Ad posted to Indeed	Payment for Indeed subscription
Payment for Transportation for Employees	Notice of benefit	Receipts showing dates and proof of payment
Staff Training or Education	Sign-in sheet for training, Copy of certificate of course completion	Signed contract/agreement with vendor, record of payment to vendor, training materials, and copy of certificate of training completion
Development of Marketing Materials	Digital or print brochures	Proof of payment for materials
Hosted Events (such as a staff lunch)	Flyer, announcement of event, event calendar etc.	Proof of payment such as credit card receipts
Employee Benefits (such as a gym membership)	Notice of benefit option	Proof of payment to vendor

Spending

It is important to keep in mind that the goal of the ARPA funding is to ensure that programs are well staffed with highly qualified and well-trained aides, nurses, home care providers and support staff to provide covered services and supports in compliance with the HCBS Final Rule.

ARPA funding may be used for:

1. Workforce: Workforce retention strategies, recruitment, and retention of a racially and ethnically diverse and culturally competent workforce and development, implementation and promotion of trainings for staff.
2. Service Support: Supplement community integration activities. Includes supplementing the cost of member transportation to and from the program and to activities that expand community integration.
3. Emergency Preparedness: Building appropriate personal protective equipment (PPE) stockpiles from state-authorized sources for ensuring that staff can deliver care in a safe and effective manner during public health emergencies.
4. Up to 5% of the total award amount may be used for administrative expenses to support implementation of grant funded activities.

ARPA funding may not be used to:

1. Supplant current or already planned expenses, or any expenses incurred prior to the beginning of the ARPA award period.
2. Pay current wage levels, including overtime, for any employees or salary increases for administrative staff or executive staff.
3. Pay wages for new staff in any role.
4. Pay for capital expenses, such as construction projects or the purchase of a vehicle.

Agencies that fail to expend funds, or expend funds on non-approved uses, may be ineligible for future awards and/or subject to recoupment of their award.

Recoupments

While the goal of the ARPA awards is to help programs remain open and maintain adequate staffing levels to provide services, a program closure may still occur. In the event of a program closure, the Department will have to recoup any unspent ARPA funds. Failure to expend the full award amount or spending that is not consistent with the ARPA guidelines may also result in recoupment.

Penalties & Audits

Programs are subject to potential audit by the same entities who audit other Medicaid funding, which includes The Office of the Medicaid Inspector General (OMIG). In those cases, if fraud, waste, or abuse are found, there may be recoupment and penalties including, but not limited to, being excluded from other funding opportunities.