What the assessment delivers, campaign-shaped.
A written sovereignty-posture document organized to support the FI's competitive positioning in the post-transition landscape. Three to six pages on the short cycle (default for CDPAP FI given the time-limited campaign shape); six to twelve pages on the long cycle if the FI is preparing for a sale, an MLTC plan partnership conversation, or a state DOH review. Named observations sourced to the FI's actual vendor stack, MLTC payer relationships, and post-transition operational reality.
Lens 1: Sovereignty differentiator vs. peer FIs in the post-transition landscape.
What does the FI's data handling, vendor stack, AI exposure, BAA-management posture, and audit-trail completeness look like compared to the publicly-observable posture of peer surviving FIs and to the PPL-routed alternative? Where is the FI demonstrably better? Where does the FI have a gap that, if closed, becomes a sales point with consumers, with personal assistants, and with MLTC plan reviewers? This lens names the sovereignty differentiators the FI can credibly claim and the gaps that are most worth closing for competitive reasons.
Lens 2: NY DOH + HIPAA + DOL audit-readiness posture, sized to a smaller FI in a more-scrutinized market.
The post-transition market is smaller and more scrutinized. State DOH is paying attention. Plaintiff's counsel is paying attention. Surviving FIs are presumed capable until they aren't. The audit-readiness posture across NY DOH, HIPAA, DOL, and MLTC plan dispute surfaces has to be defensible from day one of the new landscape. The assessment names the gaps with proportion sized to the FI's post-transition operational scale.
The threat surface, sized to surviving CDPAP FIs.
Three campaign-shaped threats specific to surviving CDPAP fiscal intermediaries in the post-2025 PPL transition landscape. The broader LHCSA threat surface still applies and is covered on the LHCSA assessment page.
Threat 1: The post-transition market is smaller, more scrutinized, and presumed-capable until proven otherwise.
Surviving FIs are operating in a market where NY DOH, MLTC plans, plaintiff's counsel, and consumer-advocacy groups are all paying more attention than they were pre-transition. The presumption that a CDPAP fiscal intermediary is operating capably is no longer automatic; it has to be demonstrable. A documented sovereignty posture is the demonstration.
Sources: NY DOH CDPAP transition announcements 2024-2025; PPL public communications on the transition; trade press coverage of post-transition FI landscape; verify current state-of-play at assessment time.
Threat 2: HIPAA, OCR, and BAA-monitoring obligations apply to the FI as a covered entity, and the post-transition restructuring may have created BAA gaps.
FIs that restructured, merged, or repositioned during the transition may have inherited BAAs from prior corporate forms, lost BAAs that didn't get re-executed, or signed new BAAs with vendor terms that haven't been carefully reviewed. Any of those gaps becomes the FI's exposure under OCR's BAA-monitoring enforcement theory. The first audit after restructuring is the one most likely to find the gap.
Sources: 45 CFR 164 (HIPAA Privacy and Security Rules); HHS OCR Resolution Agreements 2022-2025 on BAA-monitoring inadequacy; FI restructuring patterns and BAA inheritance guidance.
Threat 3: DOL wage-and-hour, personal assistant classification, and 13-hour live-in exposure compound on top of the transition restructuring.
The personal assistant employment relationship in CDPAP is unusual and class-action exposure is real. The 2013 DOL Home Care Rule and NY's Andryeyeva and Moreno line of cases apply. FIs that restructured during the transition may have inherited time-tracking inconsistencies, overlapping employment-relationship records, or wage- reconciliation gaps that plaintiff's counsel will find attractive in discovery.
Sources: 29 CFR 552 (DOL Home Care Rule); Andryeyeva v. New York Health Care Inc., 33 NY3d 152 (2019); Moreno v. Future Care Health Services, 173 AD3d 700 (2019); New York Labor Law Article 19; CDPAP regulatory framework (NY Public Health Law Article 36, NY Social Services Law).
The short cycle, default for CDPAP FIs.
CDPAP fiscal intermediary assessments default to the short cycle because the campaign is time-limited and the sovereignty differentiator is most useful when the FI can demonstrate it quickly to prospective consumers, personal assistants, and MLTC plan partners.
- Short cycle (about two hours of your time, roughly one week elapsed). Thirty-minute discovery call. Homework on your side: vendor list, current MLTC payer relationships, the specific competitive positioning question you want answered. One sixty-minute evaluation session. A three-to- six page written posture document delivered within five business days.
- Long cycle (about ten business days, deep deliverable). For FIs preparing for a sale, an MLTC plan partnership conversation, or a NY DOH review. Forty-five-minute discovery call; six-to-twelve page written document; same cadence as the long cycle on the LHCSA assessment.
Who this is for.
Surviving NY CDPAP fiscal intermediaries (post-April-2025 transition) of any size that want to lean into the sovereignty-posture differentiator in the post-transition market.
- FIs that survived the transition by restructuring and want to validate the sovereignty posture of the post-restructuring vendor stack.
- FIs that survived the transition by holding the line and want to formalize what was implicit pre-transition into a documented competitive position.
- FIs that merged or were acquired during the transition and need to reconcile inherited BAAs, vendor relationships, and operational records into a defensible posture.
- FIs in active conversation with MLTC plans about post-transition contracting and want to bring a documented sovereignty story to the table.
- FIs in active consumer-recruiting motion against PPL-routed alternatives or other surviving FIs where sovereignty posture is the differentiator.
- FIs preparing for a sale or partnership transaction where vendor-stack posture and audit-trail completeness shape the multiple.
Adjacent FI and post-transition structures
- FIs that combined with a LHCSA post-transition and now operate both service lines (also fit the LHCSA assessment).
- Personal-assistant cooperatives or worker-owned structures that emerged from the transition period.
- Consumer-advocacy organizations supporting CDPAP consumers in the post-transition landscape.
- MLTC plans evaluating their FI vendor relationships post-transition (different shape but adjacent).
Why us.
Sterling Solutions is a Westchester-based small firm operating in the same Hudson Valley communities most NY CDPAP consumers are in. We do not run on venture capital. We have published values (success.build/ethos) and a written anti-lock-in doctrine.
We are not a CDPAP fiscal intermediary and not a vendor to one. We are not selling a migration. The assessment is shaped to help surviving FIs articulate and defend the sovereignty posture they have or can build.
The personal assistant is at the kitchen table. The consumer is in the chair or in the bed. The family is in the next room. The trust at the center of CDPAP is not abstract. Surviving the transition matters because the care matters. Sovereignty posture matters because that's part of what the trust is built on now.
What this page is not.
This is not a NY DOH CDPAP regulatory compliance audit. Those exist and we are not certified to do them. We name gaps and route.
This is not legal advice. Sterling Solutions is a technology firm, not a law firm. CDPAP-specific regulatory matters should run through counsel with CDPAP expertise. Wage-and- hour matters should run through employment counsel.
This is not a PPL-comparison or PPL-migration consulting engagement. PPL is the larger context the FI is operating against; the assessment is about the FI's own posture, not about reverse-engineering PPL's.
Tire-kickers, briefly.
The evaluation is honest work. Bring the owner or operating principal who actually makes the vendor and positioning decisions, and bring a real intent to read what we deliver. Curiosity is fine. Performative curiosity is not what this offer is for.
One discovery call.
Thirty minutes for the short cycle (default for CDPAP FI), forty-five for the long cycle. The post-transition window is open now. The FIs that demonstrate sovereignty posture early in the re-sorting motion are the ones who capture disproportionate share of the consumer and MLTC plan attention. The asymmetry between having a documented posture and not is large during a market re-sorting; it compresses once the market settles.
Heads-up on the booking page: the booking widget shows 30-minute slots. For the short cycle (default for CDPAP FI), thirty minutes is the right length. If you need the long cycle, email [email protected] and we will arrange a forty-five-minute slot.
success.build/risk/home-care/cdpap-fi · [email protected] · campaign-shaped; short cycle default