The State Early Intervention Coordinating Council held a meeting on June 14 (yesterday) to accept or reject the new regulations regarding issues including the 15 minute increment billing and adjusted early intervention rate calculations.
I just finished speaking with Holly Kennedy from the EIP and she confirmed that the current rulemaking was rejected and that there will be a new rulemaking (look for the new Rules proposals in the Register around the end of June).
There will be another 45 day comment period (but no public hearings). Ms. Kennedy stated that some alternate proposals may appear in the rulemaking but she was not free to be specific about those at this time. I have some initial information about those proposals but won't publish my information until I can verify and source it.
Finally, I was told that any current service plans will continue in effect past any new rules - and will be revised on an individual basis during the regular review period.
When I get details about the new rulemaking I will post them here or if they are brief enough - on our Facebook page.
My apologies that this is more fact than analysis - but at this point I am figuring that anyone interested in this particular topic understands the issues. If there are specific questions I can address about any of this please email or comment.
I wanted to provide a link to the full meeting. It is rather lengthy, but for those who are inspired I recommend watching the section on revised rates, the section on proposed revisions (the 15 minute increment issue), and the public comment. You can access the video at http://www.totalwebcasting.com/view/?id=nysdoh
The EIP party line on proposed rate changes is that they 'can't comment' on them because they have not yet been proposed. The good news is that they scheduled some public forums to gather feedback but the bad news is that they scheduled the release of the regulation revisions AFTER the meetings.
The EIP reports that they expect to realize 6.2 million dollars in savings in FY 2012-2013 but that these savings will not represent significant changes in reimbursement. I believe this can be said with a straight face because they are operating under a general assumption that a 45 minute session length is standard. Of course it is not - as was expressed quite vociferously in the public comment period on the video.
I believe that it is dishonest to state that this level of funding cut won't be significant. I also believe that it is fundamentally dishonest to schedule public forums before the proposed changes are announced.
The jaw-dropping moment of the video happens around 182:53 when EIP Executive Director Brad Hutton stated, "I think its fair to say that actually these proposals came out of discussions at the RAP [Reimbursement Advisory Panel]... we felt like the genesis was the general public of external stakeholders." Someone needs to tell Mr. Hutton that with all the legitimate questions about following the NYS Open Meetings Law, the significant challenge with obtaining minutes of the RAP meetings, and believing that providers helped generate these back-door reimbursement cuts qualifies this statement as the Pinocchio Story of the Year.
Watching this video will help you understand that our government programs are inefficient, poorly managed, and unable to be financially maintained with all of the perpetual bureaucratic bloat and mandate.
Redux for practitioners: Continue to prepare for sea change in how you deliver your services.
Redux for families: Begin to plan for new ways to meet your children's needs.