Thursday, March 15, 2012

Will my child be eligible for services this year?

This is a common question that parents ask this time of year - many children are having their annual reviews and determinations are being made for eligibility. In an interest of making sure that all families are aware of their rights, New York State does things like releasing the new translation of revised procedural safeguards into multiple languages.

Families might want to look elsewhere for information about how eligibility determinations will be influenced in the future in NY State. In addition to focusing on translation of procedural safeguards maybe the Department of Education and Department of Health and the Governor's office should be more clear about new funding methodologies that are being considered.

I will attempt to demystify what is going on because I don't see that they are informing the public in a particularly clear way.

Last year Governor Cuomo held meetings around the state discussing plans for redesigning Medicaid. I was really hoping we would see some opportunity for impacting service delivery concerns like entrance and exit criteria, consistency in eligibility standards, and promotion of evidence-based interventions. Instead we are getting another year of smoke and mirrors widget counting in a hope and prayer to eke more money from the federal Medicaid till.

Currently, the SSHSP (Preschool/School Supportive Health Services Program) rates for services in schools are set at 75 percent of the mid-Hudson Medicare rates. The government allows several methods for coming up with reimbursement rates - either as a percentage of the Medicare rate or based on commercial rates or based on actual costs of providing the services. Apparently someone is of the opinion that there will be more money available if we start doing time and motion studies and ask for reimbursement based on actual costs incurred.

Proposal 13 was discussed last year as one possible way to realize more Medicaid revenues and was introduced as part of a larger plan to control the Medicaid budget. This proposal led to a a Request for Proposals that was announced last summer to bid on the project entitled "Cost Study and Implementation of Revised Reimbursement Methodology for the Preschool/School Supportive Health Services Program (SSHSP)." The RFP asked for a vendor who could deliver a cost study to determine whether current reimbursement for preschool and school supportive health services furnished in school districts, certain schools, and counties in New York reflects the actual cost of service delivery. The vendor also has to implement a Certified Public Expenditure (CPE) reimbursement model to enhance Medicaid reimbursement. At some point in time that contract was awarded to Public Consulting Group.

NYS released a Medicaid in Education Alert on March 1st regarding implementation of random moment time studies for the new CPE reimbursement strategy. That means that your OTs and PTs and STs will be documenting what they are doing on a daily basis and there will be more reporting requirements heaped upon providers. More concerning, there will have to be data sharing regarding salaries, fringe benefits, contract costs, equipment costs and more bureaucrats hired to track all the data. Then there will have to be some kind of formula for making sense of the very wide variety of ways that costs are incurred (direct through district salaries, billed out to BOCES, billed out to private contractors on all kinds of methods (per pupil, per service, etc.)). Given the inconsistency in cost outlays it will be very challenging to come up with a sensible cost per unit figure.

What will all this mean? The state hopes to get more money out of the federal till - and they are banking on the fact that their cost per unit will exceed the current 75% rate based on the mid-Hudson Medicare reimbursement. There will be more bureaucrats hired and there will be more number crunching to make sure that our costs will allow us to get the most possible money from the Feds. However, costs won't be allowed to go too high because that would mean that the State would have to send excess reimbursements back to the federal government.

In sum, systemic decisions about breadth of special education services will be made in accordance with maximizing federal reimbursement. Your districts will grumble about hiring more bureaucrats. Therapists will grumble about completing time studies. Agencies will grumble about having NY State stand on their necks until they release confidential or proprietary employee data on salaries and benefits.

You will go to your CSE meetings - but now you are armed with information on what is driving all of the 'reforms.'

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