The Department has removed from this regulatory package the changes to the payment of home and community-based and facility-based visits. The Department remains committed to continued examination of the EIP reimbursement methodology and intends to have more discussion about this and other proposals with its Reimbursement Advisory Panel in the coming months.
I know that a lot of people are very happy about this, but it is important that we consider all of the events that led up to this recent decision.
As I have discussed here frequently in the past there is no question that there is need to revamp billing for this program to help support collection of payments from insurance plans. The problem is that we just witnessed and experienced an extraordinarily irresponsible and haphazard attempt to fix the problem. In fact, in attempting to 'fix' the problem, the direct actions of the Early Intervention Program administrators have reduced the numbers of providers who are still willing to work with the program and there have been program closings based in part on uncertainty that was created because of real and proposed cuts.
I know many therapists who left pediatric positions, I watched programs close, and I have listened to and participated in the worried conversations of therapists who were left wondering if they would even have a program to work in. I have directly observed the creation of waiting lists for services and watched families opt for private therapy because they didn't want to wait for the EIP or they were unhappy with the fact that experienced therapists were leaving the EIP. There has been significant damage already done - and NOTHING has been done to fix the underlying administrative problems with insurance billing. Instead, we have seen the NYS government legislate looser standards so that the EIP has a better opportunity to collect payments. In other words, the government has been unable to manage with efficient operations so they changed the billing rules for themselves.
And now are providers going to feel better about this email from Mr. Hutton? What is it that people are supposed to get from this? OH NEVER MIND! WE WERE JUST KIDDING ABOUT THOSE CHANGES. SORRY THAT KIDS DON'T HAVE ACCESS TO SERVICES LIKE THEY DID BEFORE. SORRY YOU QUIT YOUR JOBS. SORRY THAT YOU CLOSED YOUR AGENCY. SORRY THAT I BLEW THIS WHOLE THING UP.
How will this irresponsible email promote a sense of stability in the program? Based on past history, why would anyone trust the EIP? This will not cause agencies to have confidence to hire therapists and the waiting lists will likely continue.
I strongly encourage Governor Cuomo to appoint EIP administrators who have experience in the real world of EIP service provision. There are many private EIP agency directors who would have a better grip on the problems facing the program and how to introduce reform in a responsible manner. No one is served by whimsical flip-flopping, publication and retraction of proposed industry-changing regs, and an apparent inability to understand the impacts that these actions have on the program and most importantly on the families who depend on the program.
Also, our Governor needs to develop an improved system of regulatory reform review. NY State had this in concept with the Governor's Office of Regulatory Reform that was established under Pataki and subsequently dismantled under Patterson and Cuomo. Although not all aspects of this program were as successful as others, in concept it provided a mechanism of regulatory review that may have prevented the Early Intervention Program regulatory debacle. These governmental entities need to engage in real outreach to the constituents BEFORE regulations are proposed. That would go a long way to promoting a reality check when new regulations are considered.
Regulations have an impact on families and children who receive services from these programs, and they have an impact on the businesses in this state that are set up to deliver these services. Someone seems to have forgotten this fact.
We had a program that had funding challenges, and now we have a program that has funding challenges and a seriously demoralized workforce that has no sense of stability. It is shameful stewardship of this very important program, and New York citizens deserve much better.