Apparently getting a jump on the legislative process, Governor Cuomo issued an Executive Order directing state agencies involved in health and other human services to implement regulations so that “State financial assistance or State-authorized payments shall not be provided for compensation paid or given to any executive by such provider in an amount greater than $199,000 per annum.”  The $199,000 limit is subject to future adjustments, and waivers can be requested.  Note also that the order does not impose a cap on compensation, only on the use of state funds to pay in excess of the cap, so the strongest impact is likely to be on entities who receive the bulk of their funding from the state. 

This blog will follow further developments, since the scope and detailed operation of this rule will depend on the specific language of the regulations enacted by the various state entities subject to the Executive Order.  Also, the Order is essentially implementing proposed legislation in the budget submitted by the Governor to the legislature.  This in turn raises the possibility that the legislature could make changes when it passes the law requested by the Governor (or even decline to pass the law), which would raise questions about the final rules.