The perils of ex post facto cost reporting

Cost accounting is boring, I understand, but I hope providers and families read this so that they can empower themselves to push back against the systematic dismantling of the NYS Early Intervention program.

As previously blogged, NYS is engaging in a cost reporting process for the early intervention program. Cost accounting is a valid tool used by a business to establish actual cost for delivering goods or services.

Unfortunately, the NYS government is going about this process in a backwards direction. Generally, the results of cost accounting projects are used to inform stakeholders about costs so that appropriate reimbursement rates can be set. However, in NYS, the rates to providers have ALREADY been cut 15% in the last year and an additional functional cut of 33% is proposed to begin on July 1 by back-door manipulation of the billing and coding system.

Why then, is the NYS Department of Health engaging in an exercise of cost accounting when reimbursement cuts have already been made?

Many early intervention services in NYS are provided by independent contractors and small agency providers. Many of these people only dedicate a small portion of their productivity to the early intervention program. For example, an independent contractor may 'pick up' a couple EI cases to supplement their other employment. Alternately, a small agency may have individual staff see a couple EI cases as part of a much larger caseload that includes private work, contracted work, or preschool work.

NYS is asking providers to ATTEST to how much of their time and resources were assigned to the EI program in 2009. It is a burdensome exercise but it is possible to extrapolate how much revenue could have been achieved in a designated time frame in 2009. It is another matter altogether to make definitive statements on how much phone use went into the EI program in 2009, or how much equipment and supplies could be partitioned off to the EI program. This kind of information might be easy for an agency that exclusively or near exclusively provides EI services, but this is data that is not accessible on an ex post facto basis by most providers in NYS.

An easy solution to this would be to make it up, or designate use based on percentage of revenue generated - but this could be wildly inaccurate - and if the actual purpose is to gather valid data on how much it ACTUALLY cost to provide a service - you can't rely on proportional assignment of expense cost.

It is an additional matter altogether to ask someone to make an attestation that information is true and correct when it is impossible to know if the information is true and correct.

This matters because we don't really know what the state is wanting this information for - after all, the cuts to the program have already occurred!

Even more disturbing, the DOH is requiring detailed and proprietary business data including building/agency assets and staffing models which effectively equates to being required to divulge a business plan. It does not seem unreasonable to require providers who take taxpayer monies to conduct cost reporting on that aspect of work that is being subsidized by the government -but is it an over-reach to also require providers to provide in depth IRS-level accounting to a state agency that has no business having access to that data and when it is unclear what that information is being used for and why it is even being collected.

The slick answer from the state remains that they want to know how much it costs to provide EI services. The real solution is to do the following:

1. Develop a model that captures the full activities from referral to discharge, completing time and resource allocation studies on the entire EI process on a case basis. Gather enough data so that broad conclusions can be made about actual costs.

2. Study the cost differences associated with different models and organizational systems of care. It is possible that they could actually LEARN something from this level of analysis.

3. Develop the model and provide training so that time and energy can be recorded in REAL time, and not done ex post facto.

There is a deeply cynical side of my analysis that does not understand why this project is being completed. There are questions that inquiring minds want to know - and I have been asking them for over a month with absolutely no direct response to the questions:

1. Why is NYS Department of Health completing a cost accounting project "to inform stakeholders of actual costs to deliver services" when the stakeholders (the legislature via budget and the Governor via back door regulation change) have ALREADY CUT THE REIMBURSEMENT RATES?

2. Why was a model of ex post facto analysis chosen when the reality is that most agencies and providers did not collect the data in the form that is being required to provide?

3. Given that this is an ex post facto dive into data that may not even exist and in fact was never before required, why designate such a constricted time frame (one month) to comply with the reporting requirements?

4. Given that this is an ex post facto dive into data that may not even exist and in fact was never before required, why choose to do this in the month of April when many agencies and providers are FULLY engaged in fiscal end-year tasks, completing other tax and reporting requirements, and most pragmatically - when all the providers are eyeball-deep in meetings to help determine levels of service for CPSE and CSE children next year?

In sum, this process is ill-timed, intrusive, burdensome, seemingly irrelevant, and deeply flawed. This is your NYS Government hard at work to make these kinds of colossally irresponsible mandates.

We plan to soar over all of this, because we know that many people whose children need help will eventually develop workarounds and find ways to access services in other ways. When schools cut access to services or when NYS cuts EI reimbursement it does not change the fact that children still need services - and we have been a community provider meeting these needs outside of the care systems when needed and through the care systems when they are available.

My deep concern is for those children and families who don't have the resources to find those other ways.


Update 5/13/11: DOH blinked over the issue of having to provide non-EIP revenue and expense information. The CFR forms ask for TOTAL expense categories and then PERCENT ALLOCATED TO EIP. In an email I expressed concern about whether it was legitimate to ask for non-EIP budget information. I received an email from DOH indicating this information did not have to be sent. I guess they changed their minds.

I am not a privacy nut, but I just don't think it is the government's business to have that level of detail on my business, outside of what is required for tax purposes of course. Certainly that information should not legitimately be required by some contractor for a specific state agency.

Question of the day: how many agencies foolishly sent the DOH all of their detailed budget that does not have anything to do with DOH business?

There is some RICH data floating around Albany today - ripe for picking if someone wants to do a deep study of business structures. My data won't be found in that pool. I encourage people to always think twice when these kinds of requests are made.

Does anyone really know what they are doing with that information, and if it will be protected and kept private?

Or can I FOIL it all? Hmmm...

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