Comments made at the NYS Medicaid Redesign Public Hearing
I was impressed with the good attendance at the public hearing and the attendees represented a Who's Who of Health Care and Human Service Providers in WNY. There were CEOs from most major hospitals, directors of community service programs, community activists, and consumers. Their interests ranged from emergency room care, medicaid transportation, primary care providers, hospital and nursing home care, residential programs for people who have developmental disabilities, mental health agencies, substance abuse agencies, and so many more.
I was deeply saddened that I was the only person there who talked about Medicaid in education and early intervention.
These comments were hashed together from old blog posts and other rantings:
If you were unable to attend the meeting you can provide online comment at http://www.health.ny.gov/health_care/medicaid/redesign/
My name is Christopher Alterio and I am a pediatric occupational therapist. Thank you for the opportunity to provide information from a street-level provider's perspective on the Medicaid program and funding for early intervention, preschool, and school special education services.
No one questions the need to reform Medicaid, but I am calling for a scientific and evidence based process to be used when reforms are being implemented.
Reform is hard but reform can be good when it is done correctly. The problem with recent efforts of cost control are that reforms are being driven by political expediency and to satisfy legal settlements. Recent cost controls have included a 10% pay cut to early intervention providers, removing minimum service requirements for some therapies, and allowing for higher student to teacher ratios in special education classes.
The problem with all these changes is that there is no evidence that indicates this is the best way to reform or modify the system. This is pure knee-jerk reaction to a budget shortfall and has nothing to do with best practices. So, as we all continue to pay for waste, fraud, and abuse throughout the system - our elected officials are making cuts to budget lines without any apparent regard for evidence. Also, these reforms are being made within the regulatory and rule making process that has some procedural safeguards for public participation but it does not seem that input into that process seems to make any difference.
Our special education system and its funding mechanism is broken and now we have a real chance to improve.
I believe that this particular situation provides an opportunity for districts to begin looking at their models of service provision and see how to provide services more efficiently. That includes setting appropriate entrance and exit criteria for related services, adopting evidence-based or RTI-type models for educational intervention, and improving team building to ensure that services are reinforced in a transdisciplinary way throughout the curriculum. All of these strategies would help improve the efficiency and also the quality of special education services. They would also by design promote cost savings and prevent Medicaid waste.
Professionals also have new opportunities to improve focus on school-home carryover. Parent involvement is critical for positive educational outcomes and may be the largest underutilized resource in the special education equation.
I am not speaking code for decreasing related services and abdicating responsibility to parents. I am talking about an open dialogue about educational best practices and establishing responsible and defensible criteria points for intervention. We have had too many years of poor oversight, lack of accountability, and variable interpretation of special education regulations. I am a practitioner who provides services across dozens of school districts and I can report that there is almost no consistency between districts in how the special education system is administered. This is shocking, particularly in consideration of the tremendous legal process and regulatory requirement that is already present in the system.
In all fairness, there is indeed a price for the fraud and abuse that has existed in this system for many years - but you do not solve the problem with fraud and abuse by failing to address the real problems. New York State has a long history of policy making on the periphery - we decrease service utilization and try to save money by layering complex rule and regulatory changes for Medicaid reimbursement - when what we need to do is establish criteria for the service utilization itself and standardize administration of the program across the State.
We cannot continue to make policy on the periphery of this problem by layering bureaucratic solutions for reimbursement at the feet of school districts or providers. When you present your report to Governor Cuomo, please include reforms that are targeted at the heart of the problem. That means that we need standard procedures, standard entrance and exit criteria, and evidence-based interventions.
Thank you very much for your consideration and for the opportunity to present this information.
I think it is important for this team to hear from more people about Medicaid reimbursement for services to children. They got an earful from every other constituency - and early intervention and education people need to show up for this conversation.