External AnalysisThe external analysis will use various framewor.docx

External Analysis
The external analysis will use various frameworks to analyze
the following: changes and trends in the environment, Porter’s
Five Forces industry analysis, competitor analysis, industry
segmentation and demand issues and opportunities in the
industry.
This section will use frameworks to describe the external
factors, such as environmental changes, industry position and
competitors, that affect Atlassian. It will include a brief
introduction to the company, changes and trends in the
environment, industry analysis, analysis of existing competitors
and industry segmentation and demand issues. These analyses
provide a description of the industry landscape, which allows
for informed and thoughtful conception of opportunities in the
industry.
P.E.S.T.E.L. Analysis
A P.E.S.T.E.L. analysis looks at six segments, political,
economic, social, technological, environmental and legal, to
describe the business climate. Political and economic changes
that affect Atlassian include Brexit and the 2016 election of
United States President, Donald Trump. These two political
events have caused the U.S. dollar to strengthen, while foreign
currencies have weakened. This is a good change for Atlassian,
as the company solely accepts U.S. dollar as payment, but
incurs costs in various foreign currencies from countries in
which it operates. Social changes include the trends of inclusion
and acceptance of all people. Atlassian is vocal about being a
proponent of inclusion for all. This is also positive for
Atlassian, as it makes the company attractive to the rising
number of consumers who support these values. Two changes in
the technology segment that affect Atlassian are cloud
computing and X-as-a-Service business models. To stay relevant
considering these trends, more companies will develop digital
products to add to their portfolio. One of Atlassian’s main

targets for its products is software development teams, so this
change will increase its number of potential customers. An
environmental trend is climate change, and the idea that
companies have corporate social responsibility (CSR) to reduce
their affect and impact on the environment. Software companies
as a rule are ‘green’, having only two main inputs: humans and
electricity. Atlassian is no exception to this rule. Potential
trends in the legal segment could have negative impacts on
Atlassian. One possibility is cyber security laws. As they
mature, Atlassian’s product development and delivery could be
impacted by higher security standards. Secondly, U.S. President
Donald Trump has proposed increased import tariffs.
Atlassian’s products are subject to U.S. import laws, and so this
could increase their expenses. Analyzing trends in these
segments provides an explanation of Atlassian’s current and
future business climate.
Industry Analysis: Porter’s Five Forces
Porter’s Five Forces model, as the name would suggest,
analyzes an industry’s attractiveness based on five forces: threat
of new entrants, power of buyers, power of suppliers, threat of
substitutes and competition within the industry. To understand
the software industry’s attractiveness, a Porter’s Five Forces
analysis has been completed. Within the software industry, the
threat of new entrants is medium. This is because it is relatively
easy to enter the software industry, with very low initial
investment costs, but it is more difficult to create a product that
will gain traction. The power of buyers is also medium. Buyers
in the software industry traditionally have had low power due to
high switching costs due to the vast scope, cost and schedule of
enterprise software implementations. The new model of monthly
subscription cloud-deployed software, however, has lowered the
cost of switching and inversely raised the power of buyers. The
power of suppliers, on the other hand, is high. The main input
for a software company is their employees. Competition for
highly skilled workers in the tech industry is extremely
competitive, and so the ‘suppliers,’ or employees, have great

power in negotiating their ‘price,’ or salary and benefits
package. The fourth force, threat of substitutes, is medium for
the software industry. The software industry is reaching
maturity, and there are many alternative enterprise software
solutions available for any industry, task and price range
imaginable. The ability to create a homegrown solution using
basic tools such as Microsoft Word and Microsoft Excel also
exists as a substitute to the software industry, especially for
small and medium businesses. The final force, competition, is
high within the software industry. As the industry reaches
maturity, and the market is saturated, the competition increases.
Existing Competitors
Within the software industry, specifically the B2B workplace
software industry, the key success factors are as follows:
product capabilities, flexibility, total cost of ownership, ease of
access and use, performance and scalability integration,
customer satisfaction and global reach (Atlassian Corporation
Plc., 2016, p. 42). Atlassian breaks its competitors into three
groups, based on the recipients of the products: IT and service
teams, software and technical teams, and business teams. The
distribution of Atlassian’s competition based on recipients of
product offerings. Competitors of Atlassian within these three
groups include Microsoft, IBM, Hewlett Packard Enterprise,
Google, ServiceNow, salesforce.com, Zendesk and several
smaller software vendors like Slack and GitHub (Atlassian
Corporation Plc., 2016, p. 42). While these companies include
some small startups and some legacy solutions, the majority are
enterprises who have been actively engaging in acquisitions of
solutions to create a ‘one-stop shop’ software solution for other
companies. Even small, niche companies could create change in
the competitive dynamic in the software industry, if acquired by
one of the tech giants to create a competitive offering.
Industry Segmentation and Demand Issues
Customer satisfaction and loyalty in the software industry is
driven by the following: product capabilities, flexibility, total
cost of ownership, ease of access and use, performance and

scalability, integration, customer satisfaction and global reach
(Atlassian Corp Plc., 2016, p.42). This general base of
customers, in which Atlassian competes well, is segmented by
various factors, namely, deployment, size of customer and
customer need. The three types of deployment are cloud, on
premise and data center solutions. Though Atlassian’s original
deployment method was on premise, they positioned themselves
early to pivot to cloud deployment, which has allowed them to
gain traction in the cloud space. Atlassian also offers data
center solutions (Atlassian Corporation Plc., 2016, p. 42),
allowing them to provide solutions for customers of all sizes,
from individuals to enterprises. Beyond knowing that they have
over 60,000 customers, and that they provide solutions for 291
of the Fortune 500 companies, the distribution of their
customers across company size is unknown, so it is difficult to
say where they are positioned in the customer size segment. The
overall customer need that the Australian software company
fulfills is software for teams. Atlassian creates team software:
IT and service teams, software and technical teams and business
teams. Atlassian, through their flagship product JIRA, is
extremely well positioned in the segment of products for
software and technical teams. The recent acquisition of Trello, a
free online collaboration software targeted at business teams is
allowing Atlassian to further position themselves into the
segment for business teams. Atlassian has footing in the
segment for IT and service teams with JIRA ServiceDesk, but is
directly competing with large, well-known companies like
Salesforce.
In an article published by S&P, “Software Industry Survey,” it
is predicted that companies in the software industry will to
increase revenue and cash, continuing the trend of the last five
years, and that gross margin will likely decline as companies
invest in cloud technology and complete acquisitions (Kessler,
2016). These acquisitions reflect a trend in enterprise
companies creating ‘one-stop shop’ solutions. This, along with

the software industry reaching maturity, indicates that low-cost
competition will soon begin. However, the workplace and
collaboration software industry specifically will likely see an
increase in potential revenue due to the increase in global
knowledge workers and the conversion of companies and
industries to digital.
Opportunities in the Software Industry
Using these frameworks to analyze the software industry and
the external environment allows for identification of
opportunities in the industry. Customers and segments that are
not well served within the current workplace collaboration
software subindustry are non-technical businesses and
consumers. The options that exist have vast features that the
average user will never utilize, but the price is reflective of the
features. Applying Clayton Christensen’s theory of disruptive
innovation, indicates that there is great opportunity at the
bottom of the market that is open for a company to fill and
begin to siphon off those lower hanging customers. Eventually,
with increasing features, the disruptive innovation will reach
the trajectory of customer needs and disrupt the traditional
legacy technology. Another opportunity that exists in the
software industry is upward vertical integration. As stated
previously, the main input in the software industry is skilled
workers, and the competition for employees is extremely high.
An interesting opportunity for a company in the software
industry, then, would be to be their own supplier of talented
workers. One way that a company could do this would be by
offering a free training program in return for an employee to
sign a contract to work for them for a specific amount of time.
This runs the risk of a company expending time and incurring
costs in an area that isn’t their core competency, but could work
if internal training content had already been developed, as is the
case for Atlassian.
QUALITY ASSURANCE AUDIT
OPWDD Internal Audit Criteria

NAME OF INDIVIDUAL:
Reviewer:Date of Review:
OPWDD Audit Criteria
Acceptable
(Yes/No)
Missing Document
Comments
A1. Level of Care Eligibility Determination (LCED) Form
Name of Individual
Address of Individual
Individual’s Date of Birth
Date of Psychological Evaluation
Date of Social Evaluation
Date of Physical Evaluation
Medicaid No. (CIN) and Tabs ID

Review Date and Signature of Qualified Person
A2. Individual Plan of Protective Oversight and Safeguards
Date of IPOP Review
Date and Signature of Qualified Personnel
Safe guards in place to protect the recipient’s health and safety.
A3. Individualized Service Plan (ISP)

Date of Annual ISP Review
Summary of Fire Safety
Type of waiver (residential habilitation), frequency of service,
duration of service and effective date service began. ISP
designates the agency (Edwin Gould) as the provider service.
Identification of personal goals, preferences, capabilities and
capacities relative to the need stated in outcomes
Valued Outcomes
Date of ISP Six Month Review
Valued Outcomes

Summary of Fire Safety
A5. IRA Residential Habilitation Plan
Name of Individual
Identification of category of waiver service provided
Date the habilitation plan was last reviewed
Medicaid No. (CIN)
Safeguards identified in the Individual’s Plan of Protective
Oversight that will be provided by the Habilitation Service
Provider

Valued Outcomes
Description of services and support being provided to the
individual
Sign-in sheet that proves that IRA Residential Habilitation Plan
was reviewed and/or revised.
The initial habilitation plan is written within 60days of the start
date of the habilitation service and forwarded to the service
coordinator.
Date and Signature and Title of Qualified Personnel
IRA Residential Habilitation Billing

ANDREW M. CUOMO
Governor
KERRY A. DELANEY
Acting Commissioner
OPWDD AUDIT PROTOCOL – DAILY RESIDENTIAL
HABILITATION
SERVICES PROVIDED IN SUPERVISED INDIVIDUALIZED
RESIDENTIAL ALTERNATIVES AND COMMUNITY
RESIDENCES
Effective July 1, 2014

Audit protocols assist the Medicaid provider community in
developing programs to evaluate compliance with
Medicaid requirements under federal and state statutory and
regulatory law, and administrative procedures
issued by the New York State Office for People With
Developmental Disabilities (OPWDD). The protocols
listed are intended solely as guidance in this effort. This
guidance does not constitute rulemaking by OPWDD
and may not be relied on to create a substantive or procedural
right or benefit enforceable, at law or in equity,
by any person. Furthermore, nothing in the protocols alters any
statutory, regulatory or administrative
requirement and the absence of any statutory, regulatory or
administrative citation from a protocol does not
preclude OPWDD from enforcing a statutory, regulatory or
administrative requirement. In the event of a
conflict between statements in the protocols and statutory,
regulatory or administrative requirements; the
requirements of the statutes, regulations and administrative
procedures govern.
A Medicaid provider’s legal obligations are determined by the
applicable federal and state statutory and
regulatory law. Audit protocols do not encompass all the
current requirements for payment of Medicaid
claims for a particular category of service or provider type and
therefore are not a substitute for a review of
the statutory and regulatory law or administrative procedures.
Audit protocols are applied to a specific provider or category of
service(s) in the course of an audit and
involve OPWDD’s application of articulated Medicaid agency
policy and the exercise of agency discretion.
Audit protocols are used as a guide in the course of an audit to
evaluate a provider’s compliance with

Medicaid requirements and to determine the propriety of
Medicaid expended funds. In this effort, OPWDD
will review and consider any relevant contemporaneous
documentation maintained and available in the
provider’s records to substantiate a claim.
New York State, consistent with state and federal law, can
pursue civil and administrative enforcement
actions against any individual or entity that engages in fraud,
abuse, or illegal or improper acts or
unacceptable practices perpetrated within the medical assistance
program. Furthermore, audit protocols do
not limit or diminish OPWDD’s authority to recover improperly
expended Medicaid funds and OPWDD may
amend audit protocols as necessary to address identified issues
of non-compliance. Additional reasons for
amending protocols include, but are not limited to, responding
to a hearing decision, litigation decision, or
statutory or regulatory change.
HABILITATION
RESIDENCES
This document is intended solely for guidance. No statutory or
regulatory requirement(s) are in any way altered by any

statement(s) contained herein. This guidance does not constitute
rulemaking by OPWDD and may not be relied on to
create a substantive or procedural right or benefit enforceable,
at law or in equity, by any person.
2
1. Missing Record
OPWDD
Audit Criteria
If no record is available for review, claims for all dates of
service associated with the
individual will be disallowed.
Regulatory
References
18 NYCRR Section 504.3(a)
18 NYCRR Section 540.7(a)(8)
OPWDD ADM #2014-01 pp. 2 & 6
2. No Documentation of Service
OPWDD
Audit Criteria
If the record does not document that a Residential Habilitation
service was provided, the
claim will be disallowed.

Regulatory
References
18 NYCRR Section 517.3(b)(2)
OPWDD ADM #2014-01 pp. 2 & 6
3. No Determination of a Developmental Disability
OPWDD
Audit Criteria
The claim for services provided in the absence of a clinical
assessment substantiating a
specific determination of developmental disability will be
disallowed.
Regulatory
References
14 NYCRR Section 635-10.3(a) and (b)(1)
14 NYCRR Section 671.4(b)(l)(i)
4. Missing Copy of Individualized Service Plan (ISP)
OPWDD
Audit Criteria
A copy of the individual's ISP, covering the time period of the

claim, must be maintained by
the agency. The claim will be disallowed in the absence of an
ISP. If the ISP is not in place
prior to the service date and in effect for the service date, the
claim will be disallowed.
Regulatory
References
14 NYCRR 635-10.2(a)
14 NYCRR 635-10.5(b)(5)
14 NYCRR Section 635-99.1(bk)
OPWDD ADM #2014-01 pp. 2, 5 & 6
5. Unauthorized Residential Habilitation Services Provider
OPWDD
Audit Criteria
If the provider is not listed on the ISP, as the authorized
provider for a specific service, the
service will be disallowed.
Regulatory
References
14 NYCRR Section 635-10.2(a)
OPWDD ADM #2014-01 p. 5
6. Missing Residential Habilitation Plan

OPWDD
Audit Criteria
The claim will be disallowed in the absence of a Residential
Habilitation plan. If no
Residential Habilitation plan is in place prior to the service date
and in effect for the service
date, the claim will be disallowed.
Regulatory
References
OPWDD ADM #2014-01 pp. 2 & 6
HABILITATION
RESIDENCES

3
7. Missing Required Elements of the Residential Habilitation
Plan
OPWDD
Audit Criteria
The claim will be disallowed if any of the seven required
elements are missing in the
Habilitation Plan:
1. The person’s (a) name and (b) Medicaid Identification
Number (CIN),
2. The Habilitation Service Provider agency name and type of
Habilitation Service
provided,
3. The date on which the Habilitation Plan was last reviewed,
4. The person’s valued outcome(s) that will be addressed
through the Habilitation
Service,
5. A description of services and supports the Habilitation
Service Provider staff will
provide to the person,
6. The safeguards identified in the Individual’s Plan of
Protective Oversight that will be

provided by the Habilitation Service Provider, and
7. The printed name, signature and title of the person who wrote
the Habilitation Plan
and the date staff signed the habilitation plan.
Regulatory
References
OPWDD ADM - #2012-01 p. 7
OPWDD ADM #2014-01 p. 5
8. Missing Residential Habilitation Plan Review
OPWDD
Audit Criteria
Claims will be disallowed if the relevant habilitation plan(s) is
not developed, reviewed or
revised as necessary at a minimum of at least once annually. At
least annually, one of the
residential habilitation plan reviews must be conducted at the
time of the ISP meeting.
Regulatory
References
OPWDD ADM #2012-01 p. 7
OPWDD ADM #2014-01 p. 5

9. Missing Residential Habilitation Service Note - Service Day
OPWDD
Audit Criteria
On any service day there must be documentation of the
individual’s presence and provision
of staff action. The claim will be disallowed in the absence of
such documentation.
Regulatory
References
14 NYCRR 635-10.5(12)(i)
OPWDD ADM #2014-01 pp. 5 & 6
10. Missing Billing Standard Element - Service Day
OPWDD
Audit Criteria
There are two standards for billing Supervised IRA-RH daily
Service Days: Presence in the
IRA and Provision of Staff Actions. The provider will
document the day present by denoting
lodging and services rendered to the individual. In addition to
documenting presence, the
Residential Habilitation staff must deliver and
contemporaneously document the delivery of
staff actions drawn from the individual’s residential habilitation
plan during the service time

(day) billed. The claim will be disallowed in the absence of
such documentation.
Regulatory
References
14 NYCRR 635-10.5(12)(i)
OPWDD ADM #2014-01 pp. 3, 4 & 5
HABILITATION
RESIDENCES
4
11. Missing Residential Habilitation Service Note -

Therapeutic/Retainer Day
OPWDD
Audit Criteria
On any therapeutic leave/retainer day there must be
documentation that the individual was
away from the residence, not receiving services from paid
residential habilitation staff, and
the purpose of the therapeutic leave or retainer day. The claim
will be disallowed in the
absence of such documentation.
Regulatory
References
OPWDD ADM #2014-01 pp. 4 & 5
12. Missing Billing Standard Element - Therapeutic Day
OPWDD
Audit Criteria
The habilitation plan should generally describe the purposes of
the therapeutic leave that
the individual uses and the general frequency of the leave. The
claim will be disallowed in
the absence of such documentation.
Regulatory
References

OPWDD ADM #2014-01 pp. 4 & 5
13. Billing For Ineligible Therapeutic Leave Day
OPWDD
Audit Criteria
On any therapeutic leave day, the individual may not receive
another Medicaid-funded
residential or in-patient service on that day. The claim will be
disallowed if another
Medicaid-funded or in-patient service was provided on that day.
Regulatory
References
OPWDD ADM #2014-01 pp. 4 & 5
14. Billing For Ineligible Retainer Day
OPWDD
Audit Criteria
A provider may bill for a retainer day for an individual who is
on medical leave from the IRA
or associated days where any other institutional or in-patient
Medicaid payment is made for
providing services to the individual. The claim will be
disallowed where the documentation
does not support the individual’s medical leave, other

institutional, or in-patient Medicaid
payment was made.
Regulatory
References
OPWDD ADM - #2014-01 pp. 4 & 5
15. Missing Required Elements in the Residential Habilitation
Service Documentation
OPWDD
Audit Criteria
The claim will be disallowed if one or more of the following
required elements are missing in
the note:
1. Individual’s name and Medicaid number (“CIN”).
2. Identification of category of waiver service provided.
3. A description of the individualized service provided by staff
that is based on the
person’s Residential Habilitation Plan.
4. The individual’s response to the service.
5. The date the service was provided.
6. The primary service location.
7. Verification of service provision by the staff person
delivering the service.
8. The signature and title of the staff person writing the note.

HABILITATION
RESIDENCES
5
9. The date the note was written.
Regulatory
References
OPWDD ADM #2014-01 pp. 5 & 6
16. Missing Residential Habilitation Monthly Summary Note
OPWDD
Audit Criteria

The monthly summary note must discuss any issues or concerns
and summarize the
implementation of the individual’s Residential Habilitation
Plan, and address how the
individual responded to the services provided during the month.
Claims will be disallowed in
the absence of the monthly summary note.
Regulatory
References
OPWDD ADM #2014-01 pp. 5 & 6
17. Billing for Services by Ineligible Provider
OPWDD
Audit Criteria
The claim will be disallowed if the agency does not have a
Residential Habilitation Medicaid
Provider Agreement.
Regulatory
References
OPWDD ADM #2014-01 p. 6
18. Failure to Forward Revised Habilitation Plan for
Residential Habilitation Within 30

Days to the Service Coordinator
OPWDD
Audit Criteria
For service dates April 1, 2012, and after, a revised residential
habilitation plan must be
sent to the recipient's service coordinator no more than 30 days
after either (a) an ISP
review date, or (b) the date on which the habilitation service
provider makes a significant
change to the plan.
The claim will be disallowed if the revised plan was not
forwarded within 30 days to the
service coordinator.
Regulatory
References
OPWDD ADM #2012-01, pp. 3
OMIG AUDIT PROTOCOL

OPWDD IRA RESIDENTIAL HABILITATION
FOR SERVICE DATES PRIOR TO 7/01/2014
REVISED 08/26/2016
Audit protocols assist the Medicaid provider community in
developing programs to evaluate compliance with
Medicaid requirements under federal and state statutory and
regulatory law. Audit protocols are intended
solely as guidance in this effort. This guidance does not
constitute rulemaking by the New York State Office
of the Medicaid Inspector General (OMIG) and may not be
relied on to create a substantive or procedural
right or benefit enforceable, at law or in equity, by any person.
Furthermore, nothing in the audit protocols
alters any statutory or regulatory requirement and the absence
of any statutory or regulatory requirement from
a protocol does not preclude OMIG from enforcing the
requirement. In the event of a conflict between
statements in the protocols and either statutory or regulatory
requirements, the requirements of the statutes
and regulations govern.
A Medicaid provider’s legal obligations are determined by the
applicable federal and state statutory and
regulatory law. Audit protocols do not encompass all the
current requirements for payment of Medicaid
claims for a particular category of service or provider type and,
therefore, are not a substitute for a review of
the statutory and regulatory law. OMIG cannot provide
individual advice or counseling, whether medical,
legal, or otherwise. If you are seeking specific advice or
counseling, you should contact an attorney, a

licensed practitioner or professional, a social services agency
representative, or an organization in your local
community.
Audit protocols are applied to a specific provider type or
category of service in the course of an audit and
involve OMIG’s application of articulated Medicaid agency
policy and the exercise of agency discretion. Audit
protocols are used as a guide in the course of an audit to
evaluate a provider’s compliance with Medicaid
requirements and to determine the propriety of Medicaid
expended funds. In this effort, OMIG will review and
consider any relevant contemporaneous documentation
maintained and available in the provider’s records to
substantiate a claim.
OMIG, consistent with state and federal law, can pursue civil
and administrative enforcement actions against
any individual or entity that engages in fraud, abuse, or illegal
or improper acts or unacceptable practices
perpetrated within the medical assistance program.
Furthermore, audit protocols do not limit or diminish
OMIG’s authority to recover improperly expended Medicaid
funds and OMIG may amend audit protocols as
necessary to address identified issues of non-compliance.
Additional reasons for amending protocols
include, but are not limited to, responding to a hearing decision,
litigation decision, or statutory or regulatory
change.

OMIG AUDIT PROTOCOL – OPWDD IRA RESIDENTIAL
HABILITATION
Revised 08/26/2016
statement(s)
contained herein. This guidance does not constitute rulemaking
by the OMIG and may not be relied on to create a substantive or
procedural right or benefit enforceable, at law or in equity, by
any person.
2
1. Missing Recipient Record
OMIG Audit
Criteria
If the recipient record is not available for review, claims for all
dates of service associated
with the recipient record will be disallowed.

Regulatory
References
2. No Documentation of Service
OMIG Audit
Criteria
If the recipient record does not contain documentation that a
residential habilitation service
was provided, the claim will be disallowed.
Regulatory
References
18 NYCRR Section 517.3(b)(2)
3. No Diagnosis of Developmental Disability
OMIG Audit
Criteria
Claims for services provided in the absence of a clinical
assessment substantiating a
specific diagnosis of developmental disability will be

disallowed.
Regulatory
References
14 NYCRR Section 635-10.3(b)(1)
4. Missing Copy of Individualized Service Plan (ISP)
OMIG Audit
Criteria
A copy of the recipient's ISP covering the time period of the
claim must be maintained by
the agency. If the copy of the ISP covering the time period of
the claim is missing, the claim
will be disallowed.
Regulatory
References
14 NYCRR Section 635-10.5(b)(6)
OPWDD ADM #2002-01, p. 7
5. Unauthorized IRA Residential Habilitation Services Provider
OMIG Audit
Criteria

If the provider is not listed on the ISP as the authorized
provider for a specific service, the
claim(s) will be disallowed.
Regulatory
References
OPWDD ADM #2002-01, p. 7
6. Missing Residential Habilitation Plan
OMIG Audit
Criteria
The claim will be disallowed if the relevant residential
habilitation plan is missing. If a
residential habilitation plan is not in place prior to the service
date and in effect for the
service date, the claim will be disallowed.
Regulatory
References
14 NYCRR Section 635-99.1(bl)
OPWDD ADM #2002-01, pp. 7-8
OPWDD ADM #2003-03, p. 2
OPWDD ADM #2012-01, pp. 2-3

HABILITATION
Revised 08/26/2016
statement(s)
any person.
3
Plan
OMIG Audit
Criteria
The IRA residential habilitation plan must contain these
required elements: the recipient's
name and CIN; the habilitation service provider agency name
and type of habilitation
service; the date the habilitation plan was last reviewed; the

recipient's valued outcomes; a
description of services and supports; safeguards provided; and,
the printed name, signature
and title of the person who wrote the habilitation plan, and the
date it was written or revised.
If one or more of the required elements are missing, the claim
will be disallowed.
Regulatory
References
OPWDD ADM #2003-03, pp. 2-4
For Services 4/01/12 and After, OPWDD ADM #2012-01, pp. 3
& 7
8. Missing Residential Habilitation Service Note
OMIG Audit
Criteria
On any countable service day there must be documentation of at
least one residential
habilitation service delivered to the recipient by IRA residential
habilitation staff. The claim
will be disallowed in the absence of such documentation.
Regulatory
References
14 NYCRR Section 635-10.5(b)(12)(iii)(e)

OPWDD ADM #2002-01, pp. 6-7
9. Missing Required Elements in the IRA Residential
Habilitation Service Note
OMIG Audit
Criteria
The claim will be disallowed if any of the nine required
elements are missing in the note: 1.
recipient's name and CIN number; 2. identification of category
of waiver service provided; 3.
description of the individualized service provided; 4. recipient's
response to the service; 5.
date the service was provided; 6. primary service location; 7.
verification of service provision
by the staff person delivering the service; 8. signature and title
of the staff person; 9. date
the note was written.
Regulatory
References
OPWDD ADM #2002-01, p. 6
10. Improper Number of Countable Service Days (Full Month)-
Supervised Individualized
Residential Alternative (IRA)
OMIG Audit

Criteria
The full month supervised IRA residential habilitation payment
shall be paid for services
provided to a recipient who receives 22 days of face-to-face
residential habilitation services.
The amount of the claim will be reduced for less than 22 days of
face-to-face service, by
reducing the full month to a half month, if at least 11 days of
face-to-face residential
habilitation services are found. The difference between the
amount of the full month rate
and the amount of the half month rate will be disallowed.
Regulatory
References
14 NYCRR Section 635-10.5(b)(9)(v)(a)
14 NYCRR Section 635-10.5(b)(12)(iii)(c)
OPWDD ADM #2002-01, pp. 2-3
HABILITATION
Revised 08/26/2016

statement(s)
any person.
4
11. Improper Number of Countable Service Days (Full Month)-
Supportive Individualized
OMIG Audit
Criteria
The full month supported IRA residential habilitation payment
provided to a recipient who is enrolled for 22 days and receives
4 days of face-to-face
residential habilitation services. The amount of the claim will
be reduced for less than 4
days of face-to-face service, by reducing the full month to a
half month, if at least 11
enrolled days and 2 days of face-to-face residential habilitation
service. The difference
between the amount of the full month rate and the amount of the
half month rate will be
disallowed.
Regulatory

References
14 NYCRR Section 635-10.5(b)(10)(iv)(a)
OPWDD ADM #2002-01, pp. 4-5
12. Improper Number of Countable Service Days (Half Month)-
Supervised Individualized
OMIG Audit
Criteria
The half month supervised IRA residential habilitation rate
provided to a recipient who meets the enrollment requirement of
11 days and receives face-
to-face residential habilitation services on 11 days. The claim
will be disallowed for less
than 11 days of face-to-face service.
Regulatory
References
14 NYCRR Section 635-10.5(b)(9)(v)(b)
14 NYCRR Sections 635-10.5(b)(12)(iii)(c)
OPWDD ADM #2002-01, pp. 3-4
13. Improper Number of Countable Service Days (Half Month)-
Supportive Individualized

OMIG Audit
Criteria
The half month supported IRA residential habilitation rate shall
be paid for services provided
to a recipient who meets the enrollment requirement of 11 days
and receives face-to-face
residential habilitation services on 2 days. The claim will be
disallowed for recipients who do
not meet the enrollment requirement of 11 days or for less than
2 days of face-to-face
service.
Regulatory
References
14 NYCRR Section 635-10.5(b)(10)(iv)(b)
OPWDD ADM #2002-01, p. 5
HABILITATION
Revised 08/26/2016

statement(s)
any person.
5
14. Recipient Absent from IRA on Countable Service Day
OMIG Audit
Criteria
The provider cannot include days that the recipient is in a
hospital, nursing home or other
government funded residential site as a countable service day.
Claims will be disallowed for
days identified as improperly countable service days while the
recipient is out of the IRA.
Note: As per ADM #2002-01, the day of admission and day of
discharge to a hospital,
nursing home, ICF, or other government funded residential site
may be counted when IRA
residential habilitation staff deliver and document residential
habilitation services. For
supervised IRAs, up to 14 days per calendar month may be
counted for a full month claim
(7 days for a half month claim) when IRA residential

habilitation staff deliver and document
residential habilitation services to a resident who is away from
the IRA for purposes of
vacation and visits with family or friends.
Regulatory
References
14 NYCRR Section 635-10.5(b)(12)(iii)(a)
14 NYCRR Section 635-10.5(b)(12)(iii)(c)
OPWDD ADM #2002-01, p. 5
15. Missing IRA Residential Habilitation Monthly Summary
Note
OMIG Audit
Criteria
A summary note shall be recorded, at least monthly, by the staff
member(s) having a
substantive responsibility for delivering or monitoring delivery
of the plan of services.
Claims will be disallowed in the absence of the monthly
summary note.
Regulatory
References
OPWDD ADM #2002-01, p. 7
OPWDD ADM #2003-03, p. 4

16. Missing Residential Habilitation Plan Review
OMIG Audit
Criteria
For dates of service prior to and including July 15, 2010, and
after March 31, 2012, claims
will be disallowed if the relevant habilitation plan(s) is not
developed, reviewed or revised as
necessary at a minimum of at least twice annually. At least
annually one of the residential
habilitation plan reviews must be conducted at the time of the
ISP meeting.
Regulatory
References
OPWDD ADM #2003-03, pp. 2 & 3
For Services 4/01/12 and After, OPWDD ADM #2012-01, pp. 3-
4
17. Failure to Write the Initial Habilitation Plan For Residential
Habilitation Service
Within 60 Days
OMIG Audit
Criteria

For residential habilitation services, the initial habilitation plan
must be written within 60 days
of the start of the habilitation service and forwarded to the
service coordinator. For dates of
service prior to and including July 15, 2010, and after March
31, 2012, the claim will be
disallowed if the plan is not written within 60 days of the start
of the habilitation service.
Regulatory
References
OPWDD ADM #2003-03, p. 2
For Services 4/01/12 and After, OPWDD ADM #2012-01, p. 2
HABILITATION
Revised 08/26/2016
statement(s)
any person.

6
18. Failure to Forward Revised Habilitation Plan For
Residential Habilitation Service
Within 30 Days to the Service Coordinator
OMIG Audit
Criteria
A revised residential habilitation service plan must be given to
the recipient’s service
coordinator no more than 30 days after either the six month ISP
review date or if the plan’s
provider makes a significant change as agreed to by the
recipient, their advocate and
service coordinator. The claim will be disallowed if the revised
plan was not forwarded
within 30 days to the service coordinator for residential
habilitation dates of service prior to
and including July 15, 2010, and after March 31, 2012. For
service dates April 1, 2012, and
after, a revised residential habilitation service plan must be sent
to the recipient’s service
coordinator no more than 30 days after either (a) an ISP review
date, or (b) the date on
which the habilitation service provider makes a significant
change to the plan.
Regulatory

References
OPWDD ADM #2003-03, p. 2
For Services 4/01/12 and After, OPWDD ADM #2012-01, p. 3
Plan Review
OMIG Audit
Criteria
For services 4/01/2012 and after, at least annually one of the
residential habilitation plan
reviews must be conducted at the time of the ISP meeting. In
addition, there must be
evidence that the Habilitation Plan was reviewed within 12
months prior to the month in
which the service occurs. Evidence of a review may include,
but is not limited to, a review
sign-in sheet, a service note indicating a review, or
revised/updated Habilitation Plan.
Evidence of reviews must include: 1) the individual’s name, 2)
the habilitation service(s)
under review, 3) the staff’s signature(s) from the habilitation
service, 4) the date of the
staff’s signature, 5) date of the review. The claim will be
disallowed if evidence of the
review is missing.
Regulatory
References

For Services 4/01/12 and After, OPWDD ADM #2012-01, pp. 3-
4, 7

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