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.