Fact check: Will new EI rules really create jobs as claimed?

Proposed rule changes for EI rates were published yesterday.

The main issue for practitioners to be aware of is that you will no longer bill for a 'basic visit' which in most cases consists of a 30 minute visit. Instead you will bill in 15 minute increments - but what is important to understand is that the rate you were previously paid will now apply to a base visit length of 45 minutes. That means that if you are continuing with your standard 30 minute visits that you will experience an additional 33% rate cut.

Whenever rule changes are proposed there needs to be impact statements - and NYS rulemakers have decided that cutting EI rates an additional 33% will result in increased job opportunities:

The proposed rule change for home and community services to full 15 minute billing increments may result in a minimal increase of employment opportunities as providers will have to align time spent delivering services with the time assumptions used to establish the rates. It may also provide an employment opportunity for providers of children who receive intensive services to provide a higher level of services through longer visits without incurring the cost of travel to a participant's home. Previously these intensive services may not have been cost effective or feasible to provide under the existing payment structure.


In other words they are stating that since providers will have to work 33% longer to make the same amount of money that this will cause agencies to hire more people to meet the same EI demand. Obviously the rulemakers have never directed an agency or owned a practice. I don't know how they can be so dishonest when they are writing these rules - it isn't even a matter of perspective - the impact statements are just dishonest.

What is more likely to happen is that agencies will not be able to hire therapists because no one will work for such a low rate and because there is no way for agencies to cover costs at current salary levels and at this low reimbursement. Current EI therapists and even entire agencies will bail out of the system and try to find work in other sectors - and indeed that will create job opportunities! No one will want to work in EI, so there sure will be a lot of EI jobs available.

On a serious note, this means that many children will not receive EI services - and that those families who have resources will access private resources/insurance to help themselves. Those families who do not have resources will be out of luck.

The bottom line here is that cost-sharing is realized because people who have resources will activate those resources and that saves the EI system and NY State money. However, the distribution of this cost-sharing is only an option for people who already have the resources - and if these rule writers knew anything about the demographics of the EI program they would understand that they just kicked a very needy population that doesn't have a lot of resources even further into the gutter.

Comments

julie said…
As a NICU OT, I try to teach the parents to the max, before their babies go home because I am not sure about how the OT follow up will be from their EIP...
Chris said…
Good call, Julie. NICU therapists often form very strong and trusting bonds with families and are in a fantastic position to serve as resources. I recall that when I was in the NICU it was difficult to help some families transition TO their EI therapists who were actually very competent.

I am sure that reality dictates you can't be in contact with all of them forever - so I hope that there are some alternate resources in the community for your families to access. I'm glad there are dedicated therapists like you out there who can help with these transitions!
Anonymous said…
Hi. As a EI therapist I was wondering if there is anything we can do to fight these new regulations
Chris said…
The 5% cut was done by budget/law - so there is nothing to be done about that now. The (larger) upcoming additional cuts effective 7/1/11 are being done by regulation. The time period to respond to the proposed regulatory changes is within 45 days of 4/14/11. Write about your concerns to
Katherine Ceroalo, DOH, Bureau of House Counsel, Regulatory Affairs Unit, Room 2438, ESP, Tower Building, Albany, NY
12237, (518) 473-7488, email: regsqna@health.state.ny.us
It is all so frustrating. Here is how I see the future - less kids receive EI services, more kids need special education services once school aged. Currently, NY state has no money to begin with. Can you imagine the influx of students with special needs in 5 years? The bottom line it is a sad situation. If these regulations go into place, perhaps we need to think about changing the model of how we delivery services. Just a thought, but parent training versus 1:1 hands on therapy may be better suited.

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