New York State HWB Program: The first employer submission period for bonuses has opened

In early August, New York State Governor, Kathy Hochul, announced the launch of the Health Care Worker Bonus Program (HWB Program). For many provider organizations, this state budget investment in frontline healthcare and behavioral health positions is warmly welcomed and recognized as highly necessary to continue to recruit and retain key healthcare, behavioral health, and support staff who not only provided crucial services over the course of the pandemic, but who also continue to deliver high quality care for New Yorkers across the state. While this funding will no doubt aid organizations in workforce recruitment and retention, there are rules and requirements in claiming the funds that must be followed and financial penalties for noncompliance. The first submission window is now open for employers, with a deadline to submit by Sept. 2, 2022. Is your organization ready to claim these funds?

Here are three considerations for healthcare providers:

1. Does your organization understand the eligibility and reporting requirements for claiming bonuses?
   The state has developed guidelines on which types of employer organizations are eligible to participate in the HWB Program, which employees qualify for a bonus under the program, and the amount of the eligible bonus based on the number of hours worked. Eligible organizations will need to understand which employee types meet criteria for bonus payments and the maximum bonus that each employee can earn. 
2. Are you ready to implement a procedure to track vesting, claims, and bonus payments per employee?
   The HWB Program will run through May 1, 2024, and employers will need to carefully track bonus claims and payments for each employee throughout the full life of the program to ensure compliance with all applicable maximum bonus payments and vesting periods. Organizations will need to be prepared to track how they have identified, claimed, and distributed bonus payments in line with these rules and regulations to ensure they are not subject to penalties and violations. 
3. Will your records withstand future scrutiny by the Office of the Medicaid Inspector General (OMIG) when payments are audited?
   The state has already announced that the Office of the Medicaid Inspector General (OMIG) will audit payments released to ensure that organizations appropriately claimed and disbursed bonus payments. The New York State OMIG has also announced that there will be monetary penalties for employers who fail to follow program guidelines. Organizations will need to clearly document and track their determinations of eligibility across all employees, claims, and payment status to ensure they can withstand any review that may arise.