New York Social Adult Day Care Documentation and NPI Requirements: MLTC Policy 25.05

MLTC Policy 25.05 is New York Department of Health guidance for how Managed Long Term Care Partial Capitation and Medicaid Advantage Plus plans oversee contracted Social Adult Day Cares. For a site that serves those members, the practical questions are the site-level organizational NPI, attendance that shows who was there and when, and the service records a plan may copy when it reviews a claim.

This article is New York-specific. ElderSuite serves adult day care centers nationwide. The rules below are not a national adult day care list, and they do not apply the same way to every New York center. Adult Day Health Care, PACE, private-pay programs, and sites with no MLTC Partial Capitation or MAP members sit under different program, payer, and contract rules.

What Policy 25.05 is — and who should pay attention

The official title is Managed Long Term Care (MLTC) Policy 25.05: Enhanced MLTC Plan Oversight of Contracted Social Adult Day Cares (SADCs). The New York State Department of Health issued it on September 08, 2025, with the same effective date. It gives MLTC Partial Capitation and Medicaid Advantage Plus plans instructions on monitoring, record keeping, and oversight of contracted SADC providers. The policy states that it does not apply to Program of All-Inclusive Care for the Elderly (PACE) plans.

The audience on the page is the plan. A Social Adult Day Care that serves those members still has to produce what the plan is told to collect: a site-level organization NPI, attendance (sign-in/out) records, service-delivery documentation, and the member’s Person Centered Service Plan.

If the center is not contracted with an MLTC Partial Capitation or MAP plan, do not treat Policy 25.05 as the house rulebook. Confirm the current packet with the plan, the contract, and the Department.

The site-level organizational NPI

Policy 25.05 told plans that, by December 8, 2025, they must require every SADC where members receive services to obtain an organization National Provider Identifier through the National Plan & Provider Enumeration System and then verify that NPI. The same policy, and the Department’s later Policy 25.05 FAQs, describe the tests the NPI has to meet:

• It is at the site and location level. If a SADC has two locations, each location must have a separate NPI.
• The physical location of the SADC is listed as the Primary Practice Address. A different business location may be listed as the Mailing Address.
• It is in the name of the SADC. A DBA may be included when appropriate. The policy’s example is “Z Corporation DBA 123 Social Adult Day Care.”
• It uses the taxonomy the Department names for SADCs: 261QA0600X - Clinic/Center - Adult Day Care.

The FAQs add that an organization may keep its organization NPI and hold a separate subpart organization NPI for each SADC.

Plans were told to report the validated NPI on the quarterly Provider Network Data System report for the quarter ending December 31, 2025, which was due January 28, 2026, and to include that validated NPI on all claim and encounter data the plan submits for members receiving SADC services.

On a claim or encounter the SADC submits, the FAQs say to put the organizational NPI in the Billing Provider field and the SADC NPI in the Rendering/Servicing Provider field. The same FAQ note says provider taxonomy codes are not required to be entered when submitting those claims or encounters. That is the Department’s claim-field instruction. It is not a description of any one billing product.

An NPI does not enroll the site with a plan, and recording a number in software does not notify NPPES or the plan. Confirm the number the plan validated for that physical location before it is used on a claim.

Attendance and service documentation

During initial and later SADC site evaluations, Policy 25.05 tells plans to collect and review attendance (sign-in/out) records that indicate, at minimum, the member’s name, the date, and start and end times. The stated purpose on the policy page is to check occupancy against the valid certificate of occupancy. Plans are also told to keep a copy of the records they reviewed. Protected health information for members not enrolled with the reviewing plan may be redacted.

The Department’s later contracting-and-oversight page uses a shorter attendance phrase: member attendance logs that include the member’s name, date, and time of SADC attendance. Policy 25.05 is the more specific of the two on start and end times.

The same policy tells plans to verify that SADCs maintain documentation required by New York State Office for the Aging regulation Title 9 NYCRR 6654.20 (d)(2)(iii) - Records, including records of service delivery, and to obtain a copy of those records for the plan’s own members. The Department’s Policy 25.05 FAQs quote that regulation. The program is to keep on file:

• administrative and financial records
• participant personal records, including identifying, emergency, and medical information including physician name, diagnosis, and medications
• services records, including the individual assessment, the service plan, and documentation of the delivery of services

Those records are to be treated as confidential.

Plans are also told to collect and review the member’s SADC Person Centered Service Plan. Policy 25.05, citing 9 NYCRR 6654.20 (d)(1)(iii)(b), states that a SADC PCSP shall be developed no later than 30 days after a member’s admission to the program and reviewed as necessary or at least once annually thereafter. The official 9 CRR-NY 6654.20 text uses the same 30-day-after-admission and at-least-once-annually language. The Department’s SADC Compliance page states that the SADC PCSP Template and User Guide were updated to begin use or alignment by the required May 1, 2026 date.

Records that support billed services

For New York adult day care billing documentation under this policy, the claim is not a stand-alone spreadsheet. The Department ties billed SADC services to:

• the validated site-level NPI on the plan’s claim and encounter data
• attendance that names the member, the service date, and the start and end times
• service-delivery records and the PCSP the plan is told to copy for its members

The FAQs say plans are required to obtain copies of service delivery records for all of that plan’s members attending the SADC. Billing questions about rates and encounters are directed, on the Department’s SADC compliance FAQ page, to the contracted MLTC plan — not to a software vendor.

What plans and reviewers may ask for

Policy 25.05 tells plans to verify a current certificate of occupancy for the correct SADC ownership and physical location before network enrollment and annually afterward, and to keep a copy. They must observe occupancy on site, review attendance, verify 6654.20 records, review PCSPs, and verify staff training under 9 NYCRR 6654.20 (d)(2)(iv)(c) and the Home and Community Based Services Final Rule, including documentation that trainings were attended. If the SADC created the training, the plan is told to obtain the training materials. When remediation is required, the plan is told to keep evidence that the SADC remediated.

The policy’s reminder is that records, supporting documentation, evidence of remediation, and SADC site evaluation tools must be maintained for at least 6 years for audit and surveillance purposes. The Department’s contracting-and-oversight page, revised April 2026, uses the same six-year period for documents and proof of remediation and says plans should be prepared to furnish that documentation within 2 business days if the Department, the Office of the Medicaid Inspector General, or the Office of Inspector General requests it.

Separately, the Department’s SADC Compliance Verification FAQs state that SADCs are required to retain member records for ten years and point readers to 9 CRR-NY 6654.20 for what to keep. That ten-year figure is a Department FAQ statement about SADC member records. It is not the same sentence as the six-year plan-file reminder in Policy 25.05. Confirm both with the current official pages and with the plan.

The Department also conducts SADC HCBS compliance reviews. Those reviews are a Department process. They are not a substitute for the plan’s own initial and annual in-person site evaluations.

How connected records help organize the file

Software does not make a New York SADC compliant with MLTC Policy 25.05. It can keep the site identifier, the day’s attendance, the signed papers, and the billed copy of that day in one place so a plan request is not a hunt through disconnected folders.

ElderSuite can help providers maintain and connect records that may be relevant:

• Provider Center opens Provider Information, the record of who the center is. National Provider ID is the 10-digit NPI that goes onto the electronic professional-claim file header, together with the Federal Tax ID. Record the site NPI the plan validated for this physical location in National Provider ID. Electronic claims carry that NPI from Provider Information. A multi-site organization should confirm with each plan how that location’s NPI is used on claims; Provider Information stores one National Provider ID.
• Client Center → Attendance & Transportation Records is the service-date attendance screen. One date, one row per client, pick-up and drop-off times. Save & Close writes the day. Those times are the arrival and departure record that later billing reads. Adult Day Care Attendance Tracking explains the connected attendance record. How to Record Attendance and Transportation Times in ElderSuite is the operating Guide.
• Client Documents holds signed and supporting client paperwork — intake forms, signed authorizations, correspondence, and other files — on the client they belong to. Give each file a Title. Adding a row only stages the file; Save & Close stores it. How to Scan Documents into ElderSuite covers the document destinations.
• Claim Center is where staff review claims, process them, read reports, and reconcile results. In ElderSuite a claim is the attendance record for that service date, so the billed day and the documented day stay on the same row. Adult Day Care Billing Software: What Providers Should Look For is the billing-workflow article.

Adult Day Care Documentation: What Records Should Your Center Maintain? is the broader records inventory. It is not New York-specific.

None of those screens is a New York certificate of occupancy, a Department evaluation tool, or a Person Centered Service Plan template. File the signed PCSP, the occupancy document the plan accepted, and any remediation proof where the next reviewer will look, including on Client Documents when the paper belongs to a client.

Confirm the current New York page

Read the current text on the Department’s MLTC Policy 25.05 page, and use the SADC Compliance site and the contracted plan for anything the policy does not settle. For how ElderSuite stores the underlying records, start with Adult Day Care Documentation.