What early intervention providers need to know about administrative rule changes, Part One

The NYS Early Intervention Program recently issues some FAQs on some regulation revisions that happened in June 2010. These changes are insidious and fly beneath the radar of most people because they constitute rules and regulations that can be administratively altered without a full deliberative process that is associated with actual changes to law/statute.

I figured I would post this today because it is a new year and I think that everyone needs to keep their ears to the ground for changes in rules and regulations that will have a significant impact on the way that health care is delivered on local, state, and federal levels.

This particular gem places additional stress on an already over-burdened New York State Budget. The regulation states that social security numbers and citizenship are required for participation in the early intervention program, BUT NOT REALLY.

June 2, 2010 - Webinar 1 - Overview of Revisions to the EI Regulations
Frequently Asked Questions

1. Question:
Are parent and child social security number required? What if a parent refuses to provide or does not have a social security number?

The social security number of the parent and the child are required. However, not having a social security number does not preclude a child from participating in the EIP. If a parent refuses to provide their social security number, the refusal should be documented in the child’s record by the Early Intervention Official or designee (EIO/D), but the program continues to be available to the family. There is no citizenship requirement for eligibility in the EIP. The Department has developed a standard form that municipalities may use for this documentation.

The purpose of requiring SS# and citizenship is so that there can be some mechanism for the state to obtain reimbursement for the services provided (private insurance or perhaps federal Medicaid).

Rather than make effort to increase reimbursement for these services, the state - via their Enforcement Arm (OMIG) - places providers in the crosshairs with a tangled array of ever-evolving documentation and billing requirements that make payment to providers less likely.

Do the math: Allow anyone into the program, whether they can pay or not. Then pinch the providers and find as many reasons as possible not to reimburse for the care that you are mandating. Does anyone really think this will lead to a sustainable service?

The large question is: What is the end game? I predict a socialized system or a mandated unionization of the EIP workforce that will functionally accomplish the same end...

...unless the citizenry starts understanding the insidious world of administrative rule making manipulation in health care that we are now entering.


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