What are Individual Directed Goods and Services (IDGS) in New York?

IDGS is a service in New York OPWDD's HCBS waiver for people who self-direct with a Self-Direction Budget. It can pay for goods and services not otherwise covered by the waiver or the Medicaid State Plan, such as community classes, some clinician services, membership dues and household appliances, when they relate to a need or goal in the person's Life Plan. A fiscal intermediary approves, pays and bills for IDGS.

How is IDGS billed to Medicaid in New York?

Under OPWDD ADM #2015-05R2, IDGS is billed in $10 units with no rounding up. Because of eMedNY limits, a claim can include at most 99 units ($990) per date of service, so larger purchases are billed across consecutive dates of service.

New York OPWDD revises self-direction goods and services rules

New York's OPWDD revised its rules for Individual Directed Goods and Services, the self-direction budget line for classes, supplies and more. The Oct. 30 memo sets seven payment tests, $10 billing units, a new request form and fixed decision deadlines.

policy · new-york · opwdd · self-direction · fiscal-intermediary · hcbs · documentation · deep-dive

Direct Support News desk · October 30, 2026 · Updated November 4, 2026 · 5 min read

New York's Office for People With Developmental Disabilities (OPWDD) issued a revised administrative memo on Oct. 30 that changes how Individual Directed Goods and Services (IDGS) are approved, paid for and documented. IDGS is the part of a self-direction budget that can pay for things like community classes, clinician services Medicaid does not otherwise cover, membership dues, household appliances that support independent living, and staff management supports.

The memo, ADM #2015-05R2, came out with a companion revision of the documentation rules for fiscal intermediaries (FIs), the agencies that bill for and pay out self-directed budgets. Most of the changes took effect when the memo was issued. The new payment-request process starts 90 days later.

Who IDGS is for

IDGS is available only to people enrolled in OPWDD's HCBS waiver who self-direct with budget authority, meaning they have an approved Self-Direction Budget. Each person who uses IDGS must pick an FI to bill and administer it.

The seven tests for payment

To be reimbursed, an IDGS purchase must:

Relate to a need or goal in the person's Life Plan.
Increase independence, or reduce the need for staff assistance that would otherwise be paid for.
Promote community living and inclusion.
Take place in an integrated community setting that meets federal HCBS settings rules.
Be safe and appropriate for the person.
Be used only by the person who self-directs.
Not duplicate supports available through Medicaid or other federally funded programs.

The memo adds definitions for "broader community," "community classes," "integrated settings" and "duplicative service." The duplication definition matters most day to day. A purchase is not duplicative just because it works on similar goals or skills as another service, includes content another service might also cover, or offers recreation or socializing another support could provide. OPWDD tells FIs to look at the actual content, purpose and delivery of what is being bought, and not to deny a request only because it overlaps in name with another service.

IDGS still cannot replace another waiver service, and it cannot pay for programs that would otherwise need OPWDD certification and oversight.

Billing in $10 units

IDGS is billed to Medicaid in $10 units, and providers may not round up. Because of limits in eMedNY, the state's Medicaid billing system, a claim can carry at most 99 units, or $990, per date of service. Larger purchases are split across consecutive dates of service.

A new form and set deadlines

Starting 90 days after the memo took effect, the FI must have a payment-request process that uses an OPWDD-approved form. The person or their representative fills it out when asking to pay a new vendor, or to buy a new item or service from a vendor already in use. Continuing payments to an approved vendor don't need the form unless the FI sees a reason it might stop paying, in which case it must ask for the form before deciding. If a person needs help with the form, their Support Broker or Care Manager must help.

The memo warns that anything bought before approval may not be paid for by the FI.

As summarized by the law firm Bond, Schoeneck & King, the review now runs on a fixed clock:

The FI must send a written decision within 15 days of getting the request. It can approve, deny or recommend a Life Plan meeting. The decision goes to the person, their representative, their Care Manager and their Support Broker.
To dispute a denial, the person must get the completed form to the FI within 30 days.
The dispute meeting generally happens within 30 days, and the person can ask for one extension of up to 30 days.
The FI decides within 15 days after the meeting.
If the FI still says no, the person can ask for an OPWDD administrative review within 30 days, and the FI must send the file to OPWDD within five business days.

When the Life Plan is the problem

If a request meets every test except a link to the Life Plan, the FI must not simply deny it. It must write to the person and their Care Manager suggesting a Life Plan update, and pause its decision for 60 days. If the plan still isn't updated within 75 days, the FI tells the Regional Field Office it intends to deny. If the field office agrees, it tells the person about their right to a Fair Hearing through the state Office of Temporary and Disability Assistance.

Records

IDGS records, including the Life Plan and service documentation, must be contemporaneous and kept for at least six years from when the service was delivered or billed, whichever is later. OPWDD recommends keeping them for 10 years because of the New York False Claims Act. The FI memo keeps the same six-year minimum and also restates when FIs can bill their own monthly fee at Level One or Level Three. It warns that spreading one month's work across several months to bill more FI fees is considered fraudulent billing.

What this means for providers and DSPs

FIs have the heaviest lift. They need the new request form, the 15-day decision letters, a dispute meeting process, and a tracking system for the 60- and 75-day Life Plan clock, all in place within about 90 days.
Care Managers and Support Brokers will see more Life Plan update requests. The plan now drives whether a purchase gets paid, so goals need to be specific enough to support what the person wants to buy.
Self-hired staff and DSPs who support people in self-direction may be asked to help gather receipts or explain how a class or item supports a goal. Purchases shouldn't be made before the FI approves them.
Agencies that also provide waiver services should note the clearer duplication test. A class or activity that overlaps with a day or community habilitation goal isn't automatically off-limits, but IDGS can't be used in place of a covered service.

IDGS is not a habilitation service, so it does not need a habilitation plan. People who self-direct and their families can read the FI memo on OPWDD's site and the full IDGS memo.