Executive Order continues limits on visitation

The Governor has released Executive Order 202.48  that, among other things, continues the state’s visitation limits for our homes. The policy restricting visitors unless the recently implemented attestation process is followed will continue beyond July 6.

Also, for child care providers licensed under social services law, this latest executive order rescinds the exemption from the criminal background check process.  This does not affect OPWDD programs which are authorized under mental hygiene law – those exemption rules remain in place.

The Executive Order continues the directive contained in Executive Order 202.41, regarding phase three industries and entities, but modifies it to prohibit indoor food services New York City.

The Executive Order also continues the suspensions and modifications of law, and any directives, not superseded by a subsequent directive, made by Executive Order 202 and each successor Executive Order up to and including Executive Order 202.14, as continued and contained in Executive Order 202.27, 202.28, and 202.38, for another thirty days through August 5, 2020, except:

  • The directives contained in Executive Order 202.3, that closed video lottery gaming or casino gaming, gym, fitness center or classes, and movie theaters, and the directives contained in Executive Order 202.5 that closed the indoor common portions of retail shopping malls, and all places of public amusement, whether indoors or outdoors, as amended, are hereby modified to provide that such directives remain in effect only until such time as a future Executive Order opening them is issued.

Further, the provisions of Articles 11-A and 11-B of the State Finance Law, and any regulations authorized thereunder, to the extent necessary to respond to the direct and indirect economic, financial, and social effects of the COVID-19 pandemic are suspended or modified through August 5, 2020.

The Executive Order discontinues, as of July 7,  the following suspensions, modifications, and directives made by previous Executive Orders, and such statutes, codes, and regulations are in full force and effect:

  • The directive contained in Executive Order 202.28, as extended, that prohibited initiation of a proceeding or enforcement of either an eviction of any residential or commercial tenant, for nonpayment of rent or a foreclosure of any residential or commercial mortgage, for nonpayment of such mortgage, is continued only insofar as it applies to a commercial tenant or commercial mortgagor, as it has been superseded by legislation for a residential tenant, and residential mortgagor, in Chapters 112, 126, and 127 of the Laws of 2020;
  • The suspension which allowed for the Commissioner of Education to reduce instructional days, as such suspensions and directives have been superseded by statute, contained in Chapter 107 of the Laws of 2020;
  • The suspension permitting providers to utilize staff members transport individuals receiving services from the Office of Mental Health or a program or provider under the jurisdiction of the Office of Mental Health during the emergency;
  • The suspensions allowing the director of the Authorities Budget Office to disregard deadlines due to a failure by a State or local authority to meet the requirements proscribed during a state of emergency, are continued only insofar as they allow a State or local authority a sixty day extension from the original statutory due date for such reports;
  • Section 390-b of the Social Services Law and regulations at section 413.4 and 415.15 of Title 18 of the NYCRR, relating to criminal history review and background clearances of child care providers;
  • Subdivision 8 of section 8-408 of the Election Law, relating to absentee voting by residents of nursing homes, residential health care facilities, facilities operated or licensed under the Department of Mental Hygiene, hospitals, or facilities operated by the VA;
  • Subdivision (28) of Section 171 of the Tax Law, to the extent that the Commissioner has extended any filing deadline;
  • The directive related dispensing hydroxychloroquine or chloroquine, as recent findings and the U.S. Food & Drug Administration’s revocation of the emergency use authorization has alleviated supply shortages for permitted FDA uses of these medications;
  • Business Corporation law sections 602, 605, and 708, as such suspensions have been superseded by statute, as contained in Chapter 122 of the Laws of 2020;
  • Banking Law Section 39 (2), as such suspension has been superseded by statute, as contained in Chapters 112 and 126 of the Laws of 2020, as well as the directives contained in Executive Order 202.9;\
  • Insurance Law and Banking Law provisions suspended by virtue of Executive Order 202.13, which coincide with the expiration of the Superintendent’s emergency regulations;
  • Sections 3216(d)(1)(c) and 4306 (g) of the Insurance Law, and any associated regulatory authority provided by directive in Executive Order 202.14, as the associated emergency regulations are no longer in effect;
  • The suspension requiring a personal appearance of the defendant, and there is consent, in any jurisdiction where the Court has been authorized to commence in-person appearances by the Chief Administrative Judge; provided further that the suspension or modification of the following provisions of law are continued:
    • The 20-day timeframe for the return date for a desk appearance ticket is extended to 90 days from receiving the appearance ticket;
    • The 45-day time limit to present a matter to the grand jury following a preliminary hearing or waiver continues to be suspended and is tolled for an additional 30 days;
    • Speedy trial time limitations remain suspended until such time as petit criminal juries are reconvened or 30 days, whichever is later;
    • Suspending the Criminal Procedure Law that would prohibit the use of electronic appearances for certain pleas, provided that the court make a full and explicit inquiry into the waiver and voluntariness thereof;
    • Allowing an incarcerated defendant to appear virtually with his or her counsel before the grand jury to waive immunity and testify in his or her own defense, provided the defendant elects to do so;
    • Suspending the Criminal Procedure Law, as modified by Executive Order 202.28, is hereby continued for a period not to exceed 30 days in any jurisdiction where there is not a grand jury empaneled; and when a new grand jury is empaneled to hear criminal cases, the criminal procedure law shall no longer be suspended beginning one week after such grand jury is empaneled;
    • Suspending the protective orders to be utilized at preliminary hearings, is continued for 30 days;
    • Suspending the use of electronic appearances for felony pleas, or electronic appearances for preliminary hearings or sentencing in extended for 30 days.

Telehealth webinar on April 17

On Friday, April 17, there will be a webinar to talk about the tools and methods clinics are using for telehealth.  Many of you may be aware of them but we thought this could be a useful way to connect and learn how all of you are doing during this time frame since we last spoke.  If you have any questions, please email Deb Williams at

There is no need to register ahead of time.  We will record the meeting so if you can’t join, the recording will be available after the close of the webex call.

The two tools to be discussed are

  2. iPad and Zoom platforms for “telehealth” audio/visual feed

Once we get through the presentations we can open the discussion for other issues – so please feel free to send me any specific questions you may want raised and we will work to get as many answers.  We have not heard yet about the clinic funding from OPWDD but advocacy continues.

Please join my meeting on April 17 at 1 p.m. from your computer, tablet or smartphone.

You can also dial in using your phone.
United States: +1 (646) 749-3131

Access Code: 311-357-005

Join from a video-conferencing room or system.
Dial in or type: or
Meeting ID: 311 357 005
Or dial directly: 311357005@ or

New to GoToMeeting? Get the app now and be ready when your first meeting starts:

Group home residents contracting coronavirus at five times the city rate

The following appeared in Crain’s Health Pulse on April 9, 2020.

The residents of group homes for people with intellectual and developmental disabilities in New York City are getting sick with Covid-19 at about five times the rate of the overall city population, according to data shared with Crain’s from a coalition of agencies that operate the residences.

The New York Integrated Network and AHRC New York City said they had confirmed 117 cases among their 2,800 residents as of April 5. Nearly two-thirds of those individuals needed to be hospitalized, and 17 people had died. The organizations reporting data operate about one-fifth of the city’s residential beds regulated by the state Office for People with Developmental Disabilities.

“These are individuals who work together, socialize together. And staff come in every day,” said Arthur Webb, executive director of New York Integrated Network. “It’s a 24/7 model. It’s been a real struggle to do containment, quarantine or isolation in the homes. These were not set up as treatment centers, unlike nursing homes.”

The coalition is hoping to receive state support to purchase more protective equipment for its workers, pay staff for overtime and get more clinical support in the homes.

The agencies also reported 92 staff members had been diagnosed with Covid-19, and three had died as of April 5.

The homes provide residential care to individuals with a wide range of conditions, including autism and cerebral palsy. To comply with state guidelines, the facilities have canceled day programming and work opportunities.

Webb attributed the higher hospitalization rate among clients to the degree to which residents have underlying conditions, such as chronic obstructive pulmonary disease and congestive heart failure.

The homes have used an existing telemedicine relationship with StationMD to keep clients out of emergency departments.

Cerebral Palsy Associations of New York State, part of the coalition, received a $13 million grant to expand telemedicine at the residences last year.

“The telemedicine has been just a fantastic added value, and fortunately we were ahead of the curve in using it,” Webb said. —J.L.

CP of NYS Day & Employment Committee Updates

TO: CP of NYS Day & Employment Committee

 Below are updates for OPWDD & ACCES-VR


The HCBS Appendix K waiver has been approved and it is very complex and will need detailed review/presentations.  

  • SEMP  is NOT INCLUDED for retainer days.  We are extremely disappointed.  The provider associations and CCOs are discussing creative/alternative ways to provide these services
  • There is a webinar tomorrow, April 9 at 2:00PM for  day hab, pre-voc and com hab providers.   If you haven’t already registered for the webinar use this link.
    1. There may be another webinar on Monday focusing on day services.  


CP of NYS joined a call with IAC, DDAWNY and the NY Alliance to discuss ACCES-VR to preserve services. Thanks to Toni Sullivan for representing CP of NYS.

The goal is to work with ACCES-VR to look at the big picture including:

·       We must take swift action and think outside of the box to preserve VR services for people who currently depend on them and for those students who will be graduating and need support in the future

·       The milestone billing concept will be inadequate to support the infrastructure and we suggest quarterly payments instead, with different deliverables

·       Deliverables will be designed to support people as they need it now and to prepare them for future job success when the pandemic and subsequent economic devastation is over

·       Guiding principles that would keep things moving forward, although quite differently, include

o   Paperless everything

o   Nearly every service to be delivered remotely (we thank ACCES-VR for being forward thinking in looking at remote service delivery and think we can do even more)

o   Implementation of electronic signatures ASAP

o   Allowing vendors to provide entry services so cases can continue to be opened

 If you have time, Jim Scutt has asked to gather some deliverables, i.e. what are you currently going in ACCES Extended and Intensive that is either currently considered a deliverable or for which you are not getting   directly reimbursed?  Please send these to Toni Sullivan by Friday.

Let me know if you have any questions.

Stay healthy!


Barbara Crosier

Vice President, Government Relations

Cerebral Palsy Associations of NYS

3 Cedar Street Extension, Suite 2

Cohoes, NY 12047

Phone:  (518) 436-0178, Ext. 104

Cell:  (518) 424-3198

Fax:  (518) 436-8619


Please note that our emails have changed. 

Please update your contact for me.  Thank you!

OPWDD Provider Update


On today’s OPWDD call, they covered the following:


  1. Willow covered the visitation document that was issued yesterday via a Commissioner’s message that reminded people that visitation restrictions remain in place, and that providers had an obligation to facilitate meaningful communication between parents and residents.
  2. Data update –  As of 5/20 – 2,611 confirmed positive cases; 2,148 lived in certified residential programs, 392 resulted in deaths; of those county breakdown over 90% downstate; similar trends 90% in certified residence; 50 or older 83%; similar sex and comorbidity breakouts to last week.  The State then took credit for their steps they’ve taken to bring down the rate of infection.
  3. Fiscal Update – Kevin Valencis reported the 1/1 and 4/1 rates have been calculated and the package is on its way through DOH and will be processed by DOB once they receive the rates from DOH and they realize it is a priority; status of retainer day units – they have received DOH calculations and provided feedback to DOH and they hope to see them out in the next few business days; they are checking on a SNAP benefits decision in the state to count unemployment income for eligibility – one Affiliate had heard from their local food stamps office that the SNAP benefit would be discontinued for a resident who receives the $600 benefit because they no longer meet income requirements for SNAP (this is a state by state decision on whether those funds would be counted for eligibility).  Can providers question/challenge the units? OPWDD said they don’t have an appeals mechanism, but they used claims data and think it’s going to prove to be correct; if there seem to be substantial issues, they may look at it. Also mentioned ISS is also using $600 unemployment payment being used in rent subsidy calculations. For changes in service levels for day retainer program, it may be handled during the reconciliation process – not promised, but they’ll look at increases in service level to see if increased units above the 6 month average can be used.   Where is self-direction budget approval? Providers have been waiting for some time – where is the guidance we’ve been promised for weeks? Will there be a retainer program for self-direction?  Any update on ICF billing? OPWDD indicated the 1115 has been submitted and is under review by CMS.
  4. Any update on guidance for reopening, particularly for those not able to comprehend the social distancing and other rules?  Jill P. explained her staff are working on a document to assist on that front.


04/01/20 OPWDD Update

In preparation for today’s call at 9 a.m., here’s the update of yesterday’s OPWDD COVID-19 call courtesy of Tom McAlvanah at IAC  – thanks to Tom for this:

Hi All,
Today’s update is as follows:

Temporary Housing: OPW is welcoming the ability for our vacant Day Hab, Respite and other sites to be developed as needed temporary housing. The rate structure is being completed as discussion continues about the population who would be given priority usage of these community resources. The first priority is for people who are returning from a hospital stay and recovering from the virus. The second group is for others who are not in need of hospitalization but also tested positive and shouldn’t return to their certified residence dispute to the inability to be quarantined effectively(such as the lack of a dedicated bathroom) A third group are those who need an emergency respite placement not due to virus; an alternate respite site would accommodate that population. The Regional Offices will be the gatekeepers for these “stabilization centers.” As the guidance is comIng, we await both the programmatic and fiscal parameters. Of course, this only works with sufficient staffing and the ability to provide the incentive they need/deserve to help work in these steps-down’ units. Leaving it there.
Day Hab Waiver Update: the work with CMS is continuing daily, and they are close to a final agreement, they say. Tomorrow looks like the final submission to CMS; we understand that CMS Directors from all over the country are working with the States, so a good deal of education(about the State, the waiver contents, etc.) comes along with this renewal and thus, more time prior to approval. Nothing more to share.

Fiscal Update: as we hear the NYS budget process is moving to completion by tonight or tomorrow, we remain on hold. Again, both of the 2% increases for Direct Support are still in there and waiting for release. Kevin V is also formulating the added increase to the Residential rate structure we have heard about, with the addition of 6 hours per day for those Residential providers that do not have Day Hab associated with the folks in that residence. Again, let’s wait for the funding formulas to see the devil in the details.

Criminal Background Checks: there is some movement, but only with certain categories of staff. If a staff person is employed in one agency, they may be able to work in a different agency through a streamlined process and turned around, in one day they say, by the Justice Center. The second category of staff that can have expedited screening will be those who have worked in other “O” agencies through a similar process. The third category is for new hires who may be able to work under supervision after they clear the SEL check. More to come with an ADM shortly.

Recoupments: an exasperating topic area. We still haven’t been able to get DOH to budge on this. The Governor’s office reiterated their position on this call that they cannot stop the cycles once the data is loaded into the system. The cash flows, the extra pay for staff, the dire need and our own spending on supplies…they hear us, but…

I’ll leave it at frustrating.

Membership phone call tomorrow at 10:05 AM.

Next OPWDD call on Friday.

One final mention, on this and the previous calls, both Parent organization reps and Self Advocacy were on the phone, which is a good thing. We then, are not the only ones voicing our concerns loudly. They also hear how limited their response has been to it all.

Have a good evening,


3/30/20 OPWDD Update -Waivers, Respite, Triage

On today’s OPWDD COVID-19 update, the following issues were covered – we’re sorry to report that there was not a lot of new information offered:

  1. Waiver Update – Retainer day payment for day hab for 30 days (until Apr. 17); developing an enhanced residential service for people in certified settings for daytime supports; COVID-19 response service, community based services to support people and families; looking at temporary emergency respite initiative.  Still in negotiations with CMS.
  2. Abiba Kindo presented the temporary emergency respite opportunities that they will be “standing up” in mostly downstate communities.   They will be sending out a response form to gather information on people who might be in need of this service, particularly people in a hospital who might be appropriate for this “step down” service. The regional office document has more information and contact information about who might be eligible for this service.  Providers asked for county by county need and the criteria OPWDD is using in making approvals.  Guidance document will be sent out this evening.
  3. Commissioner Kastner welcomed families and stated their goal is to protect the safety of people enrolled in our program, the staff and families.  Explained closure of day programs and implementation of visitation policies, leaving many people disconnected and shortages in DSPs.  He repeated once again that they follow DOH’s lead on policy and tailor it to our system.   Asked for their understanding and support. Blah, blah, blah.  When asked about the triaging of resources, where will the I/DD community stand in decisions made care and resources used for people with I/DD?  Roger Beardon responded that there are procedural protections built into the legal system to ensure care for people with disabilities, missing the point of the question – what will OPWDD do to prevent discriminatory decisions in health care resource allocation.
  4. Resources for people with I/DD and families:  there’s a new web site that is intended to be more accessible and they are working on a new list serve.
  5. Budget Update – Kevin Valenchis offered that the State’s budget focus has been to negotiate provisions that have sign off on fiscally – no additional resources added for next year and there will be a status quo budget.  Things are still being negotiated and details can change.  Expectation is that the budget will be passed on time, i.e., by April 1.

Given that not much happened on today’s call, we will hold the next call for Affiliates on Thursday, April 2 at 9 a.m. with hopes that there will be information helpful to you.

To participate in the next call, please dial:



Passcode:  489140#

3/28/20 OPWDD Update

First, attached and below are a number of important notices from OPWDD on training and health advisories re: return to work, isolation, etc.

On today’s OPWDD call:

1) Reviewed the guidance documents issued this afternoon: on releasing someone from quarantine containing DOH/CDC guidance and changes the quarantine period from 14 days to 72 hours post recovery (plus additional criteria); also return to work guidance for essential personnel and another for health care workers.  Please be sure to read carefully and understand the conditions of both.

2) How would we pay for emergency triage/residential capacity?  Programs would potentially be reimbursed at intensive respite fee – this will require claiming rules to be changed to allow for this limited period of time capability (it’s likely to be a medical leave — allowing providers to bill a retainer day).  The Commissioner clarified that these beds/places would be to take people out of the hospital to free up hospital beds and contribute to the greater good.  The Governor’s office clarified that the plan is for first priority to help people move out of the hospital and secondarily to support needs in the community – both are goals.  Criteria and mission still need to be agreed upon and more work will be done on this.  OPWDD is developing a document that provides information on what the sites need to have; how it will be staffed, etc., which should be out to folks in a few days.   There are two things going on here: relocating for isolation versus emergency housing and they need to be separated in the thinking of how they are approved.

3) Abiba Kindo explained that the crisis support teams will be repurposed to respond to COVID related emergencies, non-housing group and a separate team for housing issues; will be out in the next 48 hours.

4) PPE – heated discussion on the need; State says we have been heard and they are working to ensure all understand where we stand in the priority list with homeland security/NYS.

5) Paperwork issues – state and local DOH have been working on following this:  call the Justice Center with information; OPWDD will not collect contact information upfront, rather providers would call staff and anyone else perhaps being exposed and then follow up after the fact and let OPWDD know who you’ve contacted and if there’s any problem reaching any of those people.  Also, please advise agencies just let them know that they need one contact for reporting.

6) They are hopeful that in a future executive order to have a change in the requirements for criminal background checks in a future executive order.


3/24/20 OPWDD Update

On today’s OPWDD Update call, the following key items were presented:

  1. OPWDD is moving forward with CMS; Appendix K submitted today and it’s not subject to public comment and they expect they will soon receive authorization from CMS.  On the 1135, they are working closely on the getting both that and the 1115 waivers expanded to allow NYS the flexibility it needs to support the DD sector.
  2. OPWDD received a letter from Providers regarding COVID-19 funding priorities (attached) and OPWDD staff said they are reviewing and that they will be able to answer the points at tomorrow’s provider briefing.
  3. PPE – OPWDD is trying to help agencies triage and again told providers to put their ticket/request into the county OEM’s with specific requests.  Identify if your agency can’t take people back from hospital due to not having PPE; please get ticket number, date of submission, address of submitting agency if you want follow up assistance from the State.   Email for incident reporting:
  4. Emergency Housing Proposal – a group met with OPWDD today and will regroup tomorrow morning to provide additional feedback on the OPWDD plan/proposal.  More to come.
  5. OPWDD’s policy on people going home to their families is still under review by OPWDD regarding whether they can return to the certified home before the crisis is over; they expect to provide it soon. (IT WAS JUST RELEASED – SEE LINK BELOW/ATTACHED)
  6. If providers receive inconsistent guidance from local DOH, we have been instructed to send issues to incident management.  OPWDD is working to ensure that there are ways to ensure most recent relevant information is available.
  7. Providers identified an inability to meet Matilda’s law – there is no way any agency will be able to comply with the mask requirement.  If we don’t have the equipment – how can we comply?  OPWDD is working on guidance related to this problem.
  8. Contact tracking form – OPWDD has been working to eliminate redundancy in the form and a few of the items; the Justice Center fields will be incorporated into the form. OPWDD hopes to have an updated and streamlined process/form by Thursday.
  9. CBC flexibility – no new information at this point, but the abbreviated training guidance was issued today (see below).


Reviewed Billing rules presented on the afternoon’s webinar; implementing parts of the waiver although it hasn’t been approved by CMS. Interim guidance on retainer day billing will be provided later today – for the period 3/18/20 – 3/31/20.  Billing for retainer days must be for active participants and only for the individual’s pre-existing schedule to ensure continuity of revenue.  Can bill the regular schedule for day services, and supports provided do not need to be delivered on the days the retainer is billed – continuity of care is critical.  Use existing provider ID, use existing rate codes for half and full units for day hab and pre-voc – use existing 15 minute units for community pre-voc.  Use revenue code:  “0180 – Leave of Absence” for retainer day billing.

Flexibility and Relief Measures – services may be delivered in an alternate location to the best of our ability; day hab can be provided in residences.

Face-to-face Service delivery may be provided remotely (phone or other technology) used for com hab, prevoc, pathway to employment, support brokerage, day hab, supported employment and intensive behavioral service. Sound clinical judgment can determine use of telehealth.

Documentation:  they would like (it’s not required) documentation of what happened – service provided and start/end time, not necessarily correlated with the claim (not a formal documentation requirement).


From: <>
Sent: Tuesday, March 24, 2020 9:28 AM
To: <>
Subject: COVID-19 Interim Guidance Related to Abbreviated/Refresher Training and Recertifications

OPWDD has released the below interim guidance related to

Abbreviated/Refresher Training and Recertifications to Address COVID-19 Emergency Response:

Find more guidance on COVID-19 at the following link:

 **(Please note, OPWDD has launched its new website and the page at the above link will appear differently than it has from prior emails. All of the guidance can be found under Guidance for Providers if you scroll down the page.)


OPWDD has released the below interim guidance related to Community Outings and Home Visits:

Suspension of Individual Community Outings and Home Visits

Find more guidance on COVID-19 at the following link:

**(Please note, OPWDD has launched its new website and the page at the above link will appear differently than it has from prior emails. All of the guidance can be found under Guidance for Providers if you scroll down the page.)


From: <>
Sent: Tuesday, March 24, 2020 3:07 PM
To: <>
Subject: REVISED: COVID-19 Interim Guidance Related to Family Care Services

OPWDD has released the below revised interim guidance related to Family Care services updated on 3/24/2020:

Management of Coronavirus/COVID-19 in OPWDD Family Care Homes

Find more guidance on COVID-19 at the following link:

**(Please note, OPWDD has launched its new website and the page at the above link will appear differently than it has from prior emails. All of the guidance can be found under Guidance for Providers if you scroll down the page.)

3/26/20 OPWDD Update

On today’s OPWDD Coronavirus activities update call, the following items were covered:

  1. There was significant news on the Appendix K – OPWDD is going to be responding to CMS questions and amending the application to now include (in addition to the previously announced day services) these services in their plan for obtaining approval for retainer days billing: respite, SEMP, com hab, and self-direction with budget authority for 14 days, with another extension (from 15-30 days) through the 1115 waiver.  The waiver would be for period 3/18 – 3/31 under the K, with the 15-30 day period filing right after under the 1115 waiver; anything beyond that is yet to be negotiated, but continued retainer day payments for this additional group of services will be part of the negotiations.
  2. The providers indicated they need immediate cash relief; the old way of doing business is not going to work.  Governor’s office staff indicated that they will work on this with DOB; there is no ability to guarantee an across the board rate increase at this time given the Governor’s projection that there might be a $15 billion budget shortfall.
  3. Suspension of recoupments – Kerri Neifeld from the Governor’s office indicated that the earliest that the stop on recoupments could go into effect would be with the April 22 payment, and State would have until Tuesday, March 31 to make that happen. She is fairly confident that those recoupments will be postponed and will let us know by Tuesday for certain.
  4. PPE – It remains a significant issue. Please report orders/issues with PPE to:
  5. CAS Assessment – OPWDD will have an update for tomorrow on what the continuation of the assessments means.
  6. Tracking report – draft will be out tonight/tomorrow.
  7. OPWDD will take suggested word changes to the some of their guidance that is difficult to implement– no guarantee that they will be made, but they are looking to update as providers see appropriate.
  8. Emergency housing update – they have one provider who is interested and they are meeting internally to finalize the process.