Statement on the Fiscal Year 2021 State Executive Budget

For Immediate Release: January 22, 2020
Questions: Katelyn Andrews, Director of Public Policy, kandrews@liveon-ny.org

There are small victories to be encouraged by in Governor Cuomo’s Fiscal Year 2021 budget release. Most notably, LiveOn NY is pleased with the positive steps forward associated with $798,000 in new funds for the Wellness-in-Nutrition program; continued funding for Affordable Senior Housing capital; continued funding of $15 million to address unmet needs for seniors across the state; and $868,000 in new funds for in-home and community services for older adults. With that said, we are dismayed by the continued neglect of cost of living adjustments (COLA) for the workforce contracted through the New York State Office for the Aging (NYSOFA); by disregarding these needed wage increases, the state continues to put the human services workforce at financial risk as they age. Further, we are disheartened by the continued stagnation of the NYSOFA budget as a whole. While the proposal’s overall budget has increased by 1.9%, funds for older New Yorkers decreased by .8%, despite the fact that seniors are the fastest growing demographic in our state. Progress within our state must be enjoyed equitably across the lifespan and at LiveOn NY we know that there’s more that can and should be done to make this a reality. As budget negotiations continue, we implore the state to do more for older New Yorkers and the cost-effective system of services that serves them, while ensuring older adults are held harmless from feeling the effects of any changes to Medicaid.

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LiveOn NY in the News July-December 2019

At LiveOn NY, we work hard to make sure that the public hears about the issues affecting older New Yorkers, as well as the incredible momentum that exists as we grow old. To this aim, we are proud of each and every time we are able to share this narrative with our local communities or to comment on a topic affecting older New Yorkers.

Below are a few articles & press releases noting our work: 

December 23, 2019 “Skepticism on Proposed Changes to MTA Ride Service for the Disabled” article by Roshan Abraham in City Limits

December 13, 2019 “De Blasio Admin’s Senior Housing Production Scrutinized” article by Roshan Abraham in City Limits

November 5, 2019 “Builders warn prevailing wage for service employees will have ‘crippling’ effect on affordable housing” article by Will Brederman in Crains New York Business

October 23, 2019 “Climate Control is a Year-Round Issue at NYCHA, Especially for Seniors” article by Roshan Abraham in City Limits

October 7, 2019 “BP Adams and the New York Academy of Medicine Unveil Findings from their Boroughwide Survey of Seniors, Including Recommendations to Create ‘Age-Friendly Brooklyn’” press release from the New York Academy of Medicine

September 27, 2019 “Speaker Johnson and City Council Release Report on Zoning Tools to Speed Up ADA Accessibility in the New York City Subway” press release from the New York City Council

August 19, 2019 “With One in Seven Seniors Facing Food Insecurity, CM Chin Introduces Bill to Expand Reach of SNAP” press release from the Office of Council Member Chin

August 16, 2019 “Mayor de Blasio Announces Results of Streamlined Contracting Process for Health and Human Service Providers” press release from the Office of the New York City Mayor

Testimony on the Need for Affordable Senior Housing

The following comments were submitted to the New York City Council.

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New York City Council
Joint Hearing
Committee on Aging, Chair Margaret Chin
Committee on Housing and Buildings, Chair Cornegy
December 12, 2019
Affordable Senior Housing

Thank you to Chairpersons Chin and Cornegy, and committees, for holding this important hearing on affordable senior housing.

LiveOn NY’s members include more than 100 community-based organizations that provide more than 1,000 programs to serve older New Yorkers. These core services include senior centers, home‐delivered meals, caregiver supports, NORCs, case management and homecare. Additionally, many of LiveOn NY members develop, manage, and provide services in affordable senior housing buildings throughout the five-boroughs, as well as Nassau and Suffolk counties. Through policy efforts, LiveOn advocates to increase funding and capacity for our members to meet the needs of older adults in their communities. In addition to numerous other trainings and programs offered by LiveOn NY, we are proud to convene our Affordable Senior Housing Coalition, which works to ensure the senior perspective is represented in the larger conversation of affordable housing needs.

Background

The need for affordable senior housing with services remains as or more significant today as it was in 2016, when LiveOn NY first reported our finding that an estimated 200,000 seniors were on waiting lists for housing through the HUD202 program in New York City. Findings also showed seniors wait an average of 7-10 years for a unit to become available. It quickly became evident to LiveOn NY that seniors were not immune to the housing crisis that has taken hold of our city, as the vacancy rate continued to hover around 3%. In fact, housing challenges may disproportionately impact seniors, as many older adults live on fixed incomes that cannot keep pace with rising rents; experience mobility challenges that limit housing options within an aging rental-stock; and are found to have high rates of rent burden, with one third of individuals receiving the Senior Citizen Rent Increase Exemption (SCRIE) benefit paying more than 70% of their income on rent.

The University of Pennsylvania recently released stark findings that, without intervention, the population of individuals 65 and older experiencing homelessness is likely to balloon to almost 7,000 individuals by 2030. This is far beyond the 1,438 individuals 65 and over who spent last December in temporary shelter, as reported by City Limits. Statistics indicate that we have yet to reach the peak of the housing crisis for seniors, and increased intervention by all levels of government is needed to abate an even more disastrous scenario for the oldest among us.

Seniors First Initiative

Given the current need, LiveOn NY has been pleased to see the Administration’s clear recognition of the need for senior specific housing as demonstrated through the investments and commitments included in the Seniors First Initiative, which has most notably brought about historic commitments to the production and preservation of affordable senior housing. Through this initiative and the Senior Affordable Rental Assistance (SARA) program in particular, NYC is now home to the nation’s first LGBTQ friendly affordable senior housing developed by SAGE and partners; Queens has opened its doors to HANAC’s new environmentally friendly senior building; the Bronx welcomed WSFSSH’s Tres Puentes, which will bring significant new health care resources to the MillBrook community; and thousands of seniors, including many who had experienced homelessness, now have an affordable place to call home. 

LiveOn NY sees the SARA program, which is often utilized in conjunction with NYCHA NextGen, as an incredible success and feat for the City. However, in recognition of the significant continued need and the ability to continue to refine and improve upon current efforts, LiveOn NY respectfully offers the following recommendations:

Firstly, and perhaps most importantly, LiveOn NY strongly recommends an increase to the per-unit allocation of service funds through the SARA service program, administered by HRA. Currently, only $5,000 in funding is awarded per SARA unit that is occupied by a formerly homeless senior, which makes up 30% of a building’s units. Units occupied by seniors coming from the general Housing Connect lottery system are not eligible for any city funding for services, though it is expected that services are made available to these tenants. While LiveOn appreciates and strongly prefers the inclusive nature of the program as it stands, we do not believe that the currently-available funding is sufficient to ensure the type of robust programming that is required for older adults. 

More specifically, in order to make their budgets work, providers are often having to offer less services than are believed to be preferred by seniors or are unable to offer the predominantly female human service workers in their buildings the competitive salaries they deserve—and that providers want to give—due to the lack of funds. For example, many seniors would prefer an individual at the front desk at all times, to support the physical well-being of tenants in the event of emergency. However, most budgets cannot allow for this 24/7 service, and there is no mandate to include such a position. 

To address these challenges, and ensure funding is available for senior service providers to keep wages on pace with the recent prevailing wage increases, we recommend that HRA also make available a minimum of $3,000 per year per non-formerly homeless SARA unit, in addition to the $5,000 currently available for services for formerly homeless tenants. This funding would show a recognition from the city that older adults of all housing backgrounds can benefit from the light-touch services offered by a social worker in their place of residence. Further, the funding would recognize that while an individual might not initially present with significant need for assistance, we all can benefit from additional supportive services as we age. Finally, funding for service coordinators in senior housing is proven to reduce health care costs. In fact, LiveOn NY’s member Selfhelp Community Services recently released a study of the residents in their senior affordable housing program. The study compared Medicaid data for residents in their housing in comparison it to seniors living in the same zip codes over a two year period. This crucial research found that the seniors living in Selfhelp’s affordable housing had significantly more positive outcomes including:

• 68% lower odds of being hospitalized

• $1,778 average Medicaid payment per person, per hospitalization for Selfhelp residents, versus $5,715 for the comparison group

• 53% lower odds of visiting an emergency room compared to a non-Selfhelp resident

Secondly, the city must continue to develop new affordable senior housing on all types of land—not just sites made available through NYCHA NextGen. While the NYCHA NextGen RFPs represent a critical and welcomed opportunity for the construction of new affordable senior housing, these cannot be the only projects prioritized. Without publicly committing to ensuring room is in the pipeline for proposals from alternative sites, private investment in land or pre-development planning for affordable senior housing will slow. Lack of certainty can be a driver of cost increases or speculative actions; therefore by sharing this information, mission-driven, non-profit providers can adequately prepare to respond to new opportunities. To this point, LiveOn NY notes that we have found HPD’s team to be extremely approachable and communicative about their development timelines. However, we welcome further commitments from the Administration around senior development outside of the NYCHA NextGen program.

Thirdly, LiveOn NY recommends that the City ensure that senior housing is prioritized in its overall development pipeline, allocating additional resources as needed to ensure extremely-low income seniors can be served. Given the extensive amount of time devoted to both the land-use and construction processes, delays in closing on senior properties should not place potential developments on hold. For older adults, the value of time takes on new meaning, making the urgency of the housing crisis and the need to prioritize this particular type of housing more pronounced. If projects are put on hold due to lack of investment from other levels of government (e.g. the availability of project-based vouchers or volume cap), LiveOn recommends that the City publicly and specifically articulate the nature of these challenges to ensure that the public has the information needed to effectively advocate for said resources.

Finally, LiveOn NY recommends further coordination between city agencies—particularly DFTA, HPD, NYCHA, and City Planning—as development sites are selected with the potential to include space for senior programming. As existing senior centers continue to face increased capital needs and rent increases, and the demographics of seniors continues to shift across the five boroughs, LiveOn NY recognizes the significant opportunity to improve the senior center system through the inclusion of communal space in new affordable senior housing developments. Positively, this has been in practice in some cases; however, the process to bring a new center to life has often proven challenging, filled with both uncertainty and a lack of uniformity, despite significant effort by all involved. LiveOn NY recommends the agencies come together and develop a uniform mechanism for new developments to incorporate space for senior centers that will require city funds for operation. A critical component to this should be addressing the challenges related to the varying timelines a developer must adhere to, while simultaneously allocating funding to a center in accordance with city procurement rules. This is especially important for centers that would be developed after FY22, as the senior center RFP process will have just come to a close.

New York City Housing Authority (NYCHA)

LiveOn NY would be remiss if we did not mention the importance of increased funding for NYCHA, as public housing also represents one of the few affordable options for older adults in New York City. With the Physical Needs Assessment estimating the capital backlog to be $32 billion and the barrage of news headlines indicating the dilapidated current state of the City’s Housing Authority, it is critical that funds are made available and are well-utilized to improve living conditions for NYCHA tenants. Additionally, it is important to note that community spaces operating within NYCHA have not been immune to the capital and operational challenges plaguing the developments. The Wall Street Journal estimated $500 million in capital funding is needed for NYCHA community spaces, which include senior centers and other valuable programs for NYCHA tenants and the surrounding communities. While much emphasis has been accurately placed on the need to improve the living conditions in units within NYCHA developments—which LiveOn NY wholly supports—it is nonetheless critical that these life-sustaining services also be included in the dialogue of NYCHA related needs.

Intro 6 and Intro 225

Finally, LiveOn NY would like to express our strong support of Intro 6 and Intro 225, introduced by Council Member Barron and Council Member Brannan, respectively.

LiveOn NY has been a longstanding proponent of the City’s anti-eviction efforts, including the Right to Counsel initiative spearheaded by Council Members Gibson and Levine. We welcome and support the passage of Council Member Barron’s efforts to further protect older adult tenants from facing displacement by ensuring the City receives advance notice of planned evictions of elderly tenants in order to share legal assistance resources with said individuals.

LiveOn NY also supports Council Member Brannan’s efforts to ensure age-friendly accommodations be made by landlords in an older adult’s place of residence. It is our understanding that this effort is in line with current practices related to reasonable accommodation requirements under the City’s interpretation of the Human Rights law, and we are pleased to see continued efforts to codify this practice of providing support as requested by the older tenant.

LiveOn NY thanks Chairs Chin and Cornegy and the full committees for holding today’s hearing, and we look forward to working together in the upcoming fiscal year.

LiveOn NY Responds to DFTA's Home-Delivered Meals Concept Paper

On October 28th, 2019, the NYC Department for the Aging (DFTA) released the Home-Delivered Meals (HDM) Program Concept Paper for the upcoming Request for Proposal (RFP), anticipated to be issued in early Calendar Year 2020. After significant analysis, LiveOn NY developed and submitted the following response to DFTA for consideration:

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December 11, 2019

Ms. Michelle Biondi Contract Manager, NYC Department for the Aging 2 Lafayette St. New York, NY 10007

Dear Ms. Biondi:

On behalf of LiveOn NY and our 100 nonprofit member agencies, thank you for your leadership and commitment to making New York a better place for all of us to age. During this time of increased need, particularly among the rapidly expanding older adult population, we are grateful for your ongoing partnership and for the opportunity to provide input and support to your work.

As a membership-based nonprofit organization, LiveOn NY works to make New York a better place to age by ensuring that older people have quality community services, access to needed information, and policies that reflect their needs. Among the many critical DFTA-funded programs our members administer is the Home Delivered Meals (HDM) Program. By providing a nutritious meal to homebound individuals, this program plays a key role in delaying institutional care, and enables older adults to remain in their homes and communities.

LiveOn NY has worked to support community-based organizations for over four decades; and through that work and the feedback and organizational expertise of our members, we respectfully submit the following recommendations to the HDM Concept Paper:

Reimbursement Rates Must Reflect True Cost

Reimbursement rates for meals in the HDM program remain a high concern and primary interest to LiveOn NY. Currently, these rates not only include the cost of raw food, but are intended to cover everything required to run a successful meal delivery program, including staff, fringe, and vehicles. Unfortunately, funding limitations and structural challenges have created varying reimbursement rates that on average are insufficient to cover the true cost of the program. As a result, NYC HDM providers are forced to run a deficit in order to meet the full need in their communities. Consequently, each year, providers estimate losing thousands to hundreds of thousands of dollars on this program alone.

Firstly, because HDM contracts span multiple years—three years with the possibility of renewal for an additional three—cost escalators must be built into the programs’ budgets. While reimbursements may meet the need in Year One of the contract, without cost escalators, providers will find themselves running a deficit due to inflation and rising labor costs by Year Six. Cost escalators would help ensure that providers are able to meet rising costs each year, such as raw food, as well as offer their dedicated staff raises on an annual basis. LiveOn NY feels strongly that cost escalators should be included not only in the HDM contract, but for all government social service procurements.

Secondly, LiveOn NY strongly recommends that DFTA reimburse providers for the true cost of the meal and to fulfill the contractual obligations associated with this program, as well as for the weekend meal program. The concept paper notes that “through a public-private partnership arrangement, Citymeals on Wheels, a non-profit organization, provides funding to DFTA-funded HDM contractors to deliver weekend meals, holiday meals, and emergency food boxes.” Noting this, LiveOn NY strongly recommends that funding for the weekend meals also reflect the true cost of the provision of this service—whether that reimbursement be equal to or higher than the cost of the weekday meal. Providers should not be put in the position to run a deficit on the provision of weekend meals. Further, voluntary contributions should not be subsidizing the HDM program itself. Currently, voluntary contributions are projected into the program’s budget and lower-than-anticipated contributions counts against the program’s bottom line. Providers should not be budgeting based off of expected contributions nor should they be penalized for their HDM recipients’ inability to give. Rather, voluntary contributions should be additive towards the overall operations of the program, as is the spirit of the Older Americans Act.

Thirdly, LiveOn NY believes it may be necessary to move away from a fixed reimbursement rate per meal, as is currently the structure. While this reimbursement model may be convenient from a fiscal standpoint, there are numerous downsides to this approach. This fixed reimbursement structure inherently does not allow for the variance that comes with serving more or less meals, changes in food cost, or the impact of economies of scale, for example. The program may be better served by reimbursing providers for fixed costs separately from setting variable per-meal rates for additional reimbursements. These variable rates would still need to incorporate dual funding-models for religious and non-religious meals, as indicated in the Concept Paper.

Fourthly, we recommend that DFTA better standardize said system for reimbursement, not allowing for a difference in reimbursement methodology and structure by provider. We thank DFTA for supporting this recommendation in planning to “set fair and equitable reimbursement rates in the upcoming RFP.” Unfortunately, LiveOn currently estimates, based on publicly available data, that reimbursements now range from as little as $3.94 per meal to $14.99 per meal. This disparity among providers is a real equity concern, giving some providers an advantage over others to administer a high quality, successful program, and therefore, offers seniors better access to a quality meal depending on geography. In light of this, LiveOn NY, in partnership with United Neighborhood Houses (UNH) is working with Seachange Capital Partners to identify the true cost of a meal in New York City. Our hope is that these findings will support the work of the Department for the Aging and more accurately inform the RFP process, while ensuring an equitable system for years to come.

LiveOn NY also recommends that DFTA ensure that providers have the necessary funds to offer competitive wages to hire and retain quality program staff. With the recent increase of minimum wage to $15 and other changes in labor standards, providers are increasingly strained to offer competitive salaries. Competitive, livable wages must be constant throughout the longevity of the HDM contract, as the labor market and standards continue to evolve. Additionally, funding should also be made available to allow for substitute staff—particularly drivers—to provide coverage when program staff uses paid time off or sick days. Currently, if a staff members utilizes their much-deserved PTO or sick time, the cost to cover those shifts adversely impacts the program’s bottom line. Therefore, HDM program budgets should be funded to allow for such standard variations in cost.

Finally, LiveOn NY supports increasing meal variety in a manner that is fiscally prudent for providers and allows for providers with space limitations to remain eligible as contractors. It is especially important to incorporate a structure to account for variable costs as the Department shifts towards more meal variety. While emphasis on meal variety and cultural competency is incredibly positive, it is important to also consider the effects that this shift would have on cost-savings resulting from efficiencies achieved from economies of scale—without variance in reimbursement structure, lost efficiencies could not be adequately accounted for.

No Penalties for Use of Subcontractors

LiveOn NY recommends that providers not be penalized for the use of subcontractors. Currently, a number of the HDM program contractors rely on subcontractors to cover meals that they lack the capacity or cultural expertise to serve. The Concept Paper appears to disincentivize providers from subcontracting in some cases. This would prove an exceptionally difficult adjustment for many providers. A number of prime contractors subcontract in order to best meet specific cultural and/or religious needs in their community, outsourcing to other organizations who may have more expertise with a particular cuisine. These critical partnerships and collaborations can only strengthen the surrounding community, and therefore should not be considered a disadvantage in their application.

It is also critical that non-profit subcontractors receive adequate funding to provide services without incurring a loss. DFTA must ensure passthrough of the full amount of associated funding to non-profit subcontractors, minus the indirect rate. DFTA must continue to assess the adequacy of this funding and ensure a sustainable, equitable funding pattern for both the prime-contractor, who administers this contract, and the sub-contractor, who provides the associated services.

LiveOn NY also recommends allowing non-profit providers to cater across contracts or to act as commissary meal providers. This may be especially fruitful in the provision of additional meal variety and in incorporating fresh-chilled meals, as is alluded to in the Concept Paper.

Flexibility in Number of Delivery Days

LiveOn NY recommends that the number of delivery days not affect applicants’ scores when applying to DFTA’s HDM Request for Proposal. LiveOn NY stresses this due to our significant concern around the potential shift to less delivery days per week, as displayed by the statement that “the [case management agency] is responsible, during the full assessment, for determining if the older person is capable of managing the receipt of multiple meals twice a week in lieu of a hot meal daily.” It is common for some meal recipients to not have a microwave, or not have the ability to safely heat and reheat meals. Therefore, fresh chilled meals do not address this concern, as they are defined in the Concept Paper as “prepared meals that are to be refrigerated and reheated later,” and are different from a cold meal (e.g. salad or sandwich). Additionally, while it may be that a client is initially assessed as capable of receiving meals, an unexpected health crisis might quickly reverse that finding, creating challenges as CMAs currently lack the funding capacity to significantly increase the number of assessments.

LiveOn NY is concerned that clients could become more isolated if the number of delivery days is tapered down—as isolation remains a greater predictor of morbidity than cigarettes. While a percentage of individuals may be capable of receiving multiple meals at one time, the face-to-face interaction with HDM recipients must remain an important facet of this program, which is inherently a social-services program in addition to a hunger-relief program. For the majority of individuals, albeit brief, this is the only social interaction they have all day. The face-to-face interaction with immigrant older adults could be particularly important; for example, a 2013 report by the Center for an Urban Future shows that more than 90 percent of both Korean and Chinese American seniors in NYC speak English less than very well. Because of this, they tend to be more isolated, meaning the social interaction of a daily check-in can be especially impactful for these HDM recipients. Further, it is unsurprising that many seniors may not similarly report an emphasis on social interaction as this would equate to articulating loneliness or a lack of social connectedness—a task that would be difficult for any individual.

Additionally, daily delivery provides an opportunity to regularly confirm the wellbeing of participants—many of whom are fall risks—observe changes over time, and mitigate possible threats to an individual's wellbeing. Many providers report numerous emergency situations being found and addressed as a result of this daily check-in. Currently, there is no other structure in place to fill the gap that would be left in the wake of a decrease in delivery days, as case management agencies themselves are regularly overburdened, with significant case loads and even waiting lists that wax and wane throughout the year.

LiveOn NY also expresses the need to ensure cultural competency is adhered to in the manner in which certain meals are delivered. As an example, from a cultural competency standpoint, Korean meals are generally meant to be served hot, and may not maintain the intended taste profile if chilled and reheated. In particular, a hot soup called “gug” is one of the most basic facets of a Korean meal and is served as a daily to Korean HDM recipients; it is infeasible, unfortunately, to serve this particular soup at a varied temperature. Meals that are unable to be properly frozen or chilled, must be taken into consideration when determining the number of delivery days.

Lastly, a move toward less delivery days could have a significant impact on HDM providers’ staffing. For new HDM providers, recruiting and hiring employees to deliver only two days a week could prove difficult; and for experienced HDM providers, a reduction in employment days could lead to the loss of valued employees who have been loyal to their organizations despite low pay and lack of significant raises.

Each community is unique, and the community-based organizations who contract with DFTA are therefore uniquely positioned to best understand the needs of their community and respond accordingly. Because the clientele and even meal routes vary so vastly from neighborhood to neighborhood, HDM providers must have the flexibility to administer their program appropriately.

DFTA Must Make Significant Capital Investments

One of the biggest needs across all current HDM program contractors is capital funds. In particular, there are four areas in which capital funding could improve both cost and operational efficiency:

1. Resources available for adoption of route/delivery technology

   Currently, providers find themselves using pen and paper to track their routes and delivery data. As a result, data tracking and entry proves to be an onerous task. With each program delivering hundreds of meals each day, this lack of technology is a true barrier to the efficiency of these programs. While we were thrilled to see recognition of the need for new technology in the Concept Paper, LiveOn would like to note that there is a software already being used by home-delivered meal providers across the country called ServTracker. This technology update would eliminate manual reconciliation, provide GPS mapping, and allow for real-time tracking and service delivery changes. DFTA should provide funding to invest in existing software like ServTracker, which will vastly improve efficiency and allow contractors to focus on what matters most: the older adults receiving these meals.

2. Funding availability to increase kitchen capacity and storage space

   For many community-based organizations in New York City, kitchen capacity and storage space are incredibly limited. Because there is a large focus on expanding meal variety for HDM recipients in this Concept Paper, providers have expressed concern regarding the kitchen space and storage capacity it would take to procure an increased variety of meals. For this reason, LiveOn NY recommends capital funds be made available as necessary to properly outfit kitchens so they are able to meet these requirements.

3. Investment in appliances for fresh chilled meals

   The Concept Paper defines fresh chilled meals as “prepared meals that are to be refrigerated and reheated later.” The paper explicates the difference between fresh chilled meals and a typical cold meal, such as a sandwich or salad, and notes that the shelf-life (if refrigerated at a proper temperature) of a fresh-chilled meals is 5-7 days. While many providers expressed interest in the addition of this option as a way to improve quality, there was also concern about their ability to operationalize this. In order to ensure meals remain fresh for 5-7 days, HDM providers would need to prepare and plate meals differently. Possibly the best way to do this would require a specific type of machinery known as modified atmosphere packaging (MAP). This new type of equipment extends the shelf-life of food products without the need for preservatives or freezing, and without affecting the texture of foods. While the option of a fresh-chilled meal could certainly be an improved alternative to frozen meals, HDM providers would need additional funding to purchase the equipment. The type of MAP machine required for a kitchen that prepares hundreds of meals each day would cost anywhere from $35,000 to $125,000 each depending on the meal capacity of the machine. It is critical that capital funding be made available to cover the full cost of this equipment for all providers seeking to utilize the fresh chilled meals option.

4. Technology investments and improvements to streamline communication between HDM providers and Case Management Agencies

   Both HDM providers and case management agencies use PeerPlace for client data. At present, these two DFTA-funded services, although so closely linked, must communicate about shared clients in a time-consuming and inefficient way. For example, if a case manager notes a change in condition from a recent visit, the only way he or she can communicate this finding is by sending an email to the HDM provider separate from their case notes. In order to provide a more streamlined, consistent, and informed service to HDM recipients, it would be helpful to have a mechanism—preferably through PeerPlace, a data system both are already using—to share important client updates with each other, while continuing to keep sensitive case notes private. LiveOn NY believes that improved communications between systems will lead to better outcomes for clients and efficiency of time and resources for providers.

Support for Group Purchasing

From witnessing the value of GPOs firsthand, LiveOn NY supports DFTA’s recommendation that GPOs be a critical cost-savings mechanism in the program’s future; however, we recognize that this will not act as a silver bullet to controlling all costs. LiveOn NY is proud to offer the Marketplace to members, a Group Purchasing program that creates significant savings on food and supplies, we are happy to expand this practice and work with the Department for the Aging to meet the goals of the new procurement.

Provide Funding for Sustainable Food and Products

Additionally, LiveOn NY applauds the emphasis in sustainability found in the Concept Paper. As the sourcing of products and food shifts to becoming more sustainable, LiveOn emphasizes the need for commensurate funding for associated variance in costs. We also emphasize flexibility for providers in catchment areas where local sourcing might be more difficult; this program feature might be best served on an individualized contract basis.

LiveOn NY greatly appreciates that private fundraising will not result in reductions in a program’s public funding level. We are hopeful that this includes any voluntary contributions received.

DFTA Should Explore New Revenue Opportunities

We recommend that the Department for the Aging look into ways to bring new revenue into the program. For example, a potential way to bring new revenue into the program is to allow for the provision of meals through private-pay options, as recently made allowable by the New York State Office for the Aging. For caregivers whose older loved ones may not be inherently eligible for the program, paying to opt in to a trusted meal-delivery service by local community-based organizations may be a desirable investment. Finally, the Department for the Aging might decide to support providers with capacity to cater meals to other government programs, such as Universal Pre-K, as a means of expanding organizational services and revenue sources. If kitchen spaces would otherwise go unused during portions of the day, this allowance could create efficiencies beyond the DFTA system.

Conclusion

Again, LiveOn NY is incredibly grateful for the opportunity to provide feedback on the Home Delivered Meals Concept Paper, and look forward to an RFP process that allows for innovative approaches to serving the City’s diverse older adults. We thank you for your ongoing partnership, and look forward to working together to ensure New York City’s HDM program is the strongest it can be.

LiveOn NY Opposes Another Cut to SNAP

LIVEON NY PUBLIC COMMENT OPPOSING RECENT SNAP PROPOSAL, WHICH WOULD END OR DECREASE BENEFITS FOR MILLIONS OF SENIORS

The following comments were submitted to The Food and Nutrition Service (FNS) on Monday, December 2, 2019. The FNS is housed within the US Department of Agriculture (USDA) and is the federal agency responsible for administering the Supplemental Nutrition Assistance Program (SNAP). This proposed rule on Standardization of State Heating and Cooling Standard Utility Allowance would cut nearly $4.5 billion in benefits over five years, causing 19 percent of SNAP households to get lower SNAP monthly benefits, and would disproportionately impact older adults and individuals with disabilities.

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LiveOn NY respectfully expresses our strong opposition to the proposed rule on the Standardization of State Heating and Cooling Standard Utility Allowances (SUA). LiveOn NY is a nonprofit membership organization representing 100 community-based organizations serving older adults in New York City. We also provide direct assistance to older New Yorkers through our Benefits Outreach Program, through which our team screens individuals for eligibility and assists through the entirety of the application process.

Currently, SNAP is one of our nation’s most effective anti-poverty programs, helping more than 38 million people in the United States meet their basic nutritional needs every month. However, if this proposal passes, this would mean a reduction of $4.5 billion over 5 years in benefits. Seniors and the disabled will particularly bear the brunt of this proposal, especially those who are low income and reside in communities of color. This proposal to standardize SUA will have dire consequences for many of our clients, particularly homeowners, a population that skews older, and tenants who pay utilities separate from their mortgage or rent. It is estimated that an overall 19 percent of current recipients would see their monthly SNAP benefits decrease, making it harder to afford sustenance. For some of our clients in particular, their SNAP benefits would diminish considerably—as much as $40 to $50 per month on average. Even worse, some of our clients would no longer be eligible to receive SNAP at all. 

One of LiveOn NY’s current clients receives the minimum SNAP amount of $16 per month even with the highest SUA level. Prior to the passing of his wife, he was receiving $194; but this amount was lowered to $16 after the rent reduction he received from his SCRIE redetermination. Our client is a diabetic who cannot afford the proper dosage of his medication because of the high out of pocket cost. To make his medication last longer, he splits his pills and uses his daughter’s extra blood glucose test strips. If this Standardization of State Heating and Cooling Standard Utility Allowances (SUA) passes, our client would be at risk of no longer receiving SNAP benefits. The struggles faced by our client is just one illustration of a problem plaguing countless older adults, who find themselves having to choose between food, medicine, and housing.

The SUA calculations are also tied to the eligibility for the Home Energy Assistance Program (HEAP), which helps defray the cost of heating in the winter. Standardizing SUA could have the unintended effect of making it even more difficult for older adults to pay their utility bills, because these same seniors who become ineligible for SNAP would also become ineligible for HEAP. 

“It is impossible to say that older adults in our nation have the opportunity to live with dignity and respect when so many would be at risk of going hungry due to this proposed rule.”

Moreover, the proposal to cut SUA would only put even more older adults at risk of food insecurity, which could have severe repercussions to their health, such as contributing to an increased risk of falls, which can lead to significant health care complications and costs. In the case of our client mentioned above, the stress and the lack of funds for medication could aggravate pre-existing chronic conditions, and therefore be responsible for worsening health outcomes. These cuts would also negatively affect the bottom line of local businesses and farmers from whom SNAP recipients purchase their fresh foods. Therefore, this proposal will not only be economically detrimental to older adults, but for the community at large.

At LiveOn NY, we believe that older adults should have the opportunity to age in place with dignity and respect. Every city and town in America should allow for older adults to thrive given all that they have contributed and continue to contribute to their communities. The SNAP program is a core safety net that ensures that. It is impossible to say that older adults in our nation have the opportunity to live with dignity and respect when so many would be at risk of going hungry due to this proposed rule.

As a result of our forty years of experience working with older New Yorkers, we believe that this proposal will harm, instead of help, older Americans. We urge the Federal government to withdraw this proposal in its entirety. We remain resolved in our continued efforts to advocate for policies that will safeguard against hunger, ensure housing, promote health and address economic inequality; and we are hopeful that a similar resolve will compel the Federal government to conclude that this proposal is not worth further pursuing.