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?

Answer:
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.

Comments

Post a Comment

Popular posts from this blog

On retained primitive reflexes

Each year I receive several emails from colleagues about 'retained primitive reflexes.'  I am also seeing an increased number of reports from local 'health care' providers who are documenting these alleged problems so I thought I would write a summary of my opinion on this topic.   Predatory 'health care' providers including some OTs, PTs, chiropractors, and behavioral optometrists are creating a new 'market' for treating this alleged 'problem.'  Parents should be very wary of these practitioners and other professionals should challenge these practices whenever they are seen. The following is the kind of information that causes concern and was provided to me by a colleague as a sample from a student's IEP: The student continues to demonstrate the following retained primitive reflexes that at times interfere with his ability to demonstrate appropriate adaptive responses: Fear Paralysis Reflex, Moro Reflex, Palmer Reflex, Tonic Labyri...
Read more

Deconstructing the myth of clothing sensitivity as a 'sensory processing disorder'

Please note first that there is no formally recognized clinical designation of  'sensory processing disorder.'   It is a term constructed by occupational therapists that has not been formally recognized by the larger medical community. In our clinic we receive many referrals from local pediatricians when parents have concerns about children being overly sensitive to their clothing.  Most often the children referred are from four to seven years old and the families are severely disrupted by the children's behaviors and responses to clothing issues.  Commonly, children will have severely constricted tolerance for certain outfits, want to wear the same clothes repeatedly, complain that clothing is itchy/scratch/bumpy/wiggly/ouchie, and this all leads to disruption of daily dressing routines.  There is no doubt that the behavioral concerns are very real. The pediatricians tend to be appropriately conservative and provide families with good behavioral manage...
Read more

Occupational therapy education: How to navigate in a Perfect Storm

Image
Please click on and read all of the links - they include critical information that is required for this analysis.   A little over four years ago I stated that there are too many occupational therapy educational programs in New York State .  At the NYSOTA conference legislative information session in 2023 I stood up and suggested that we should all stop taking jobs at these institutions that were seeking to develop new programs.  I thought that if we did not take those jobs that the problem would be solved.  That was not realistic or correct, even if the intention was good. Well karma tends to strike when you make public pronouncements, so I thought I should expand on my perspectives on this topic. At current count there are still ~22 occupational therapy programs and ~11 occupational therapy assistant programs in NY.  Most of the programs are delivered at the master's level.  There are a very small number of entry level doctoral programs, but some of t...
Read more