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AGING AND DISABILITY SERVICES ADMINISTRATION

December 30, 1998

BH No. 98-007B
RE: Year 2000 Compliance

Dear Boarding Home Administrator:

A letter addressing issues related to what has become commonly known as the "Y2K problem" or the "Millennium Bug" is being sent to all residential care providers licensed by the Aging and Disability Services Administration (AASA).

This letter (1) identifies and defines the Y2K problem, (2) briefly describes the steps that AASA is taking regarding Y2K problems, (3) briefly describes the various responsibilities of AASA and you regarding Y2K matters.

AASA views the Y2K problem as a potential emergency for residential facilities and their residents. It is expected that residential care providers will take the necessary steps to ensure that the health and safety of residents is not jeopardized by the Y2K problem. Steps may include but are not limited to: ensuring Y2K compliance of all vital services, equipment, or processes; replacing vital services, equipment, or processes that are not Y2K compliant; and ensuring that contingency plans are in place to continue vital services in the event of a Y2K-related failure.

What is Meant by the "Y2K Problem"?
In general, the Y2K problem refers to concerns that relate to the ability of computer programs and other systems to operate effectively into the next century. The Y2K problem has been widely discussed in the media and by other government agencies.

The Y2K problem arose because many computer programs use only the last two digits to refer to a year. These computer programs assume all years begin with "19" and may not properly handle those which should begin with "20".


The Y2K problem is not limited to computers, but can extend to any device with an "embedded chip", a computer chip with the year programmed into it. Embedded chips are found in everything from microwaves to metal detectors.

There is widespread concern that Y2K technology problems may cause significant problems with the national and world economies. Virtually all businesses and government agencies have the potential of being affected by the Y2K problem.

The Y2K problem has been addressed by the Health Care Financing Administration ("HCFA"), which is the Department’s counterpart in the federal government. In a letter to state Medicaid directors dated March 6, 1998, HCFA warned that failure to ensure Y2K compliance "could result in dire consequences for beneficiaries’ access to care, provider payments, and increased vulnerability to fraud and abuse."


What Steps is Washington State Taking With Respect to Y2K?
Governor Locke has directed state agencies to ensure that the Year 2000 causes no disruption of vital public services and no loss of accountability for public resources. As the year 2000 approaches, AASA is reviewing its critical systems and services and is working to eliminate any identified Y2K deficiencies. AASA also is working with other agencies in an attempt to ensure that all critical government functions continue to operate into and beyond the year 2000.

Washington State has developed a Y2K-related Web Site that may assist state agencies, state contractors and licensees, and others to identify potential problems and to develop plans to correct problems. The Web address is:
http://www.wa.gov/dis/2000

There are also other web sites which may provide useful information regarding Y2K preparedness. One site was developed by the Gartner Group, an organization that provides consultation on a variety of issues, including the Y2K problem.

Another site has been developed by the Emergency Management Division of the State of Washington Military Department. That address is:
http://www.wa.gov/mil/wsem

AASA has not verified the accuracy of information contained by the above mentioned web sites.

What Does AASA Expect From Residential Care Providers?
AASA expects that residential care providers will ensure that the health and safety of residents in their facilities is not jeopardized by the Y2K problem. AASA will require that you take steps to ensure the Y2K compliance of your computer systems, facilities, and operations. In addition, we will require that you have contingency plans in place in case external systems such as power, water, food or medical service delivery, or financial systems are disrupted due to the Y2K problem. These plans should be part of the emergency and disaster plans you are already required to have under 42 CFR 483.75(m) and WAC 388-78A-055(1)(a). You should consult with your local emergency preparedness agencies as you develop your plans.

AASA recognizes that issues related to Y2K can be complex and technical. At the same time, AASA believes that contractors and licensees have an obligation to ensure that critical services to residents are not interrupted.

It is not necessary for you to contact us regarding this issue. Instead, AASA may review your plans regarding Y2K compliance as part of its standard on-site visits to your facility.

What Systems Generally Require Y2K Compliance?
AASA believes that contractors and licensees must ensure that all their vital business systems are Y2K compliant. This includes computer systems as well as non-information technology systems.

AASA agrees with HCFA, which has stated that all internal systems, external systems, and interfaces must be Y2K compliant. This includes, but is not limited to, business components such as the following:

  1. Applications (including cross-business applications and all external interfaces/databases);
  2. Computer infrastructure (including hardware, system software, telecommunications, and date-dependent functions such as passwords, accounts, and software licenses); and
  3. Systems, other than "information technology" systems, that have "embedded chips" (including physical plant security systems, card-entry systems, elevator systems, environmental control systems, and medical equipment).

What are the Responsibilities of AASA and Residential Care Providers?
It is the responsibility of each provider to ensure continued, uninterrupted services despite any potential problems with Y2K compliance. AASA's role is one of oversight; thus, AASA assumes no liability for any problems that contractors may encounter with respect to Y2K compliance issues.

Conclusion
If you have questions about this letter, you may contact your area manager. Thank you in advance for your assistance with this important matter.

Sincerely,

Patricia K. Lashway, Director
Residential Care Services

Enclosure