Whitewashing the status of the NYS Early Intervention Program

In response to questions by members of the Legislature as part of the February 3, 2014 Joint Budget Hearing on the 2014‐15 Executive Budget for Health/Medicaid, the New York State Department of Health Early Intervention Program provided a progress report with the transition to the State fiscal agent.

No one stopped to think that self-assessment for progress reporting might not be the most accurate measure. 

Perhaps the most shocking misrepresentation in the report was regarding timeliness of payment.  They report that 2013 fourth quarter mean time to payment was 14 days following claim submission.  As a mean involves calculation including all ranges of payment, reporting a number without capturing the full range of data is a an absolute statistical manipulation.  A more reasonable and reliable statistic is to look at second quarter payments, which hopefully have all been compiled and adjudicated, except for extreme outliers.  That statistic is that the mean payment time was 47 days, which is much more consistent with reality that I have experienced.

I would like to congratulate the Department of Health for finding a way to report that their fourth quarter payments are happening within 14 days of billing.  It is a stunning claim and I suspect that they are hoping we have a dumbed-down legislature who all have heads swimming with common core math methodologies.  Reasonable people will understand that reporting descriptive statistics without gathering a full range of data is like patting yourself on the back for catching a nice large mouthed bass that you put in your own fish tank.

Only in government can you make such a vacuous claim and consider it reasonable.

Try this unreported statistic on for size:  In 2012 the total number of claims to the Early Intervention Program was 7,815,366.  In 2013 the total number of claims to the Early Intervention Program was 7,220,073.  According to the report, the 'claims' statistic is a proxy measure for the level of services delivered to children.  The statistic that is not reported is that there was an 8% decrease in the number of claims in 2013.  It would be hard to state that everything is 'just fine' if you talk about that inconvenient truth - so they just left that statistic out of the report.  Maybe they hope that people won't be inspired to do the math.

How about this: The number of billing providers decreased from the start of the Fiscal Agent process in March 2013 from 1,509 providers to the December 2013 level of 1,027 providers.  DON'T WORRY, says the Department of Health!  They tell us in the report "The decline in the number of billing and rendering providers from Q3‐2012 to Q2‐2013 reflects the removal of inactive providers from the EIP provider database at the time the Department implemented the 4/1/13 changes in the program and established direct agreements with each provider."  OF COURSE they have some magical way of knowing that these are all inactives?  And NONE of that 30% loss had anything to do with the State takeover and Providers bailing out of the system?  Again, it is an insult to everyone's intelligence and an obviously lopsided claim in an attempt to paint a picture in the best possible light.

Interestingly, the number of rendering providers over the course of the last year has been stable.  The Department of Health just can't help itself from trying to shine up this statistic: "This likely reflects a consolidation of rendering providers in the program into fewer billing agencies and independent providers while maintaining level capacity of rendering providers in the program."  Doesn't that sound innocuous and cozy?

Here is the reality: the reason why the numbers of rendering providers stayed essentially constant and the number of billing providers decreased is BECAUSE THE DEPARTMENT OF HEALTH SYSTEMATICALLY DESTROYED THE PRIVATE BUSINESSES OF SMALL AND INDEPENDENT PROVIDERS.  The small and independent providers had nowhere else to turn, so they were subsumed into large agencies, and their entrepreneurship has been CRUSHED.

We just won't talk about the fact that these small and independent providers were almost all women-owned private businesses, because that would contradict Governor Cuomo's claims of NY being a business-friendly environment.

Here is a final statistic that requires some analysis.  According to the report, 89% of all claims in December 2013 were adjudicated within two months.  That is up from 55% in May 2013.  That sounds good on paper, doesn't it?  Almost 90% of claims are being paid within two months - and there was a lot of improvement since the start of the Fiscal Agent Process!  Here is a little business lesson for everyone - and I hope the fine people in the legislature can understand this.  There is this little thing in business called a profit margin.  That profit margin is the amount of money that businesses get to keep for themselves after all the expenses are paid.  According to an article in Forbes, the average profit margin for therapy offices was 10.6% (http://www.forbes.com/sites/brettnelson/2011/02/10/the-most-profitable-small-businesses/).  This number might sound small to people but it is a rather healthy margin in context of most businesses.  However, that margin reflects the performance of a full range of therapy businesses.  I suspect that private PT offices make a lot more money than an early intervention service.  Still, that 90% payment level within two months takes on a very different meaning when you see that the margins for these companies are now under constant threat.  This is particularly true with early intervention, where the VAST majority of costs are going directly into staffing - and guess what - staff who work for an agency are not interested in being told that NY State hasn't made a payment yet.  Again, the reality is that the payments used to be FULL and IN REGULAR TIME INCREMENTS.  Now they are not - and that is precisely why there was a die-off of small and independent practices and this is also why even the large agencies are under duress.

Again, the Department of Health attempts to sweep all this information under the rug.  They applied a band aid to the problem last year in the form of the so-called 'Safety Net Payments.'  As the Department of Health is a governmental agency they obviously fail to understand that businesses are not interested in barely scraping by and trying to subsist on the band aid solution of a Safety Net Payment.  Again, none of this is reported on or analyzed correctly.

So we have a total whitewashing of the status of the New York State Early Intervention Program.  Don't expect anything to change, because Governor Cuomo is happy to have everyone gnashing their teeth over fracking and marijuana.  Trust me, he is hoping people won't learn the real truth about what he has done to Early Intervention.

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