EARLY INTERVENTION PROVIDER DISCUSSION AND LUNCHEON

MAY 13, 2015

Topic:Financial Sustainability in a Fee-for-Service Environment

1.What difficulties have you experienced over the past 6 years regarding the rate structure for reimbursement with NJDOH? Have you changed your delivery of services due to the impact of the rate structure for reimbursement form NJDOH? Please be as specific as possible?

SUMMARY: Providers have experienced difficulties related to the fiscal operations of their organizations. They have streamlined the way they do business in order to stay in business. Cuts in operations usually resulted in retention issues, lower productivity, not enough practitioners, and hiring of staff either per diem/consultants which has been challenged by the DOL, resulted in rate competition and geographical selectivity. The responses from the six groups are as follows:

RESPONSES

  1. Providing less services +1 does not equate to the shortage of Practitioners
  2. Losing practices to school districts or other agencies that pay higher +5
  3. Transitioning to contract staff +4 plus it raises issues with DOL. Are they acting like employees?
  4. Hiring of part time employees +1
  5. Increased benefit costs resulting in cuts or higher co pays +2
  6. Increased business costs
  7. Increased training and mentoring cost +3
  8. Geographic issues +3
  9. Productivity demands and impact of cancellations +2
  10. Affordable Care Act costs
  11. Inconsistent schedules +1
  12. Not offering benefits (including travel reimbursement)
  13. No cancellation fees are an issue +3
  14. Billing issues and new electronic billing impact, unfunded mandates +2
  15. Retention Issues
  16. Inequality of payment streams: FFS vs Grant funding

2.Given the rate experience noted in the "Related Financial Information" below, quantify and describe any "business expenses" (e.g. insurance, pay raises, travel, supervision, overhead, etc.) that you have had to absorb during the periods of time where no increases were received. What did you have to do in order to make that happen? (exact dollar amounts are not necessary; approximate percentages will suffice)

SUMMARY: Groups reported similar actions in order to sustain the financial integrity of their organizations. The responses are below.

RESPONSES

  1. Absorbed increased expenses
  2. Gave little to no pay increases
  3. Limited postage and travel reimbursement
  4. Froze or cut secretarial or office support staff
  5. Worked on clean bills so not to delay payments
  6. Lessened service quality oversight
  7. Decreased role of administrative staff
  8. Moved to independent contractors
  9. Absorbed costs of computer, equipment

3.What unfunded mandates (e.g., Supervision Manual, Fraud, Waste and Abuse, Autism Curriculum, etc.) have you been asked to pay for and absorb since the rate study conducted by the NJDOH back in 2003? Can you estimate time? Cost? Materials?

SUMMARY: The consistent theme was “is the state proactively paying attention to all their unfunded mandates?”

RESPONSES

  1. Autism Curriculum
  2. Fraud, waste and abuse
  3. DCP and P children (challenges with scheduling timely rates)
  4. TET: annuals, exits, assessments
  5. System continues to grow
  6. Children are coming in on BDI with more significant delays
  7. ABA curriculum
  8. Supervision and Observation
  9. Investigations
  10. Mandated to work
  11. IFSP-PSO-time lost
  12. New forms training
  13. Staff meetings- space, refreshments, time for staff, gas
  14. Overhead
  15. Quality Assurance
  16. Credentialing
  17. Data Entry system
  18. Information on Doctors that advocate for EI

4.What additional research data would be helpful to better understand this issue?

SUMARY: All groups agreed that a studies need to be conducted on cost effect models and rates.

RESPONSES

  1. New grads availability
  2. Rate study across the field
  3. Electronic improvements for billing and notes/storage space
  4. Should Service Coordination become FFS?
  5. Cost study 2003—what is it costing agencies to service?
  6. How are other states funding EI programs?
  7. Centered based services help families who are isolated. Is there data to support that?
  8. How many agencies have to change to part time/per diem to sustain operations?

**Related Financial Information:

  • July 2003-Early Intervention rates for providers were set based upon a rate study performed by consultants to the NJ Department of Health & Senior Services
  • 2004-Rates were increased by 2.9% for providers based upon the increase of the Medicare Economic Index in the year of the percentage. New rates were effective in January 2004.
  • October 2005-Rates were increased by $0.88 per hour due to increased gas prices. The average increase for all individual practitioners was 1.02%.
  • 2008-Rates were increased in the budget by 3%, effective January 2008.
  • January 2010- Early Intervention providers received a 5% cut in hourly rates. The rate-cut brought hourly reimbursement below the dollar amount they were receiving in 2004.

Topic:No Provider Available Policy and Procedure

1.Do you think that the current NJEIS Policy No. 08 provides adequate direction as to the process for delivering services when there is "No Provider Available"? What specifically is confusing and/or not applied consistently across the state?

RESPONSES

There is NO statement in policy referencing

  1. that services are to be withheld until the first child is served
  2. that the parent selects the time
  3. that a “declination of service” is not defined
  4. that the EI clinician is “not allowed” to pick up and offer alternatives
  5. that there are inconsistencies in policy, practice and interpretation

2.What specific disadvantages does the existing NJEIS Policy No. 08 create for families and service providers?

RESPONSES

1. The child sits on a list by the REIC and SC waiting for service. Are they getting private services?

2. State does not appear to be honoring the immediacy of the child’s needs

3. Practitioners who can take a child have to wait for the first child served. Meanwhile, that Practitioner goes elsewhere

4. Other options like virtual therapy are not statewide

5. The practice of serving every child at any time is not practical

6. Practitioners hold out for agency B because the rate they receive can be higher

7. The broadcast is shared with Practitioners and shouldn’t be

3.Give suggestions as to how you change the NJEIS Policy to create a more equitable solution and/or service options that will reduce or eliminate the NPA problem in the state. (e.g., including service providers in the development of the plan, etc.)

RESPONSES

1. State needs to clarify their policy and be consistent in implementation

2, State should not hold children hostage by making them wait until the first child is off the list and served

3. Having two comprehensives is a problem that needs to be addressed.

4.What additional research data would be helpful to better understand this issue?

RESPONSES

  1. What is the actual percentage of NPAs across county, region and with providers?
  2. What is the number of licensed therapists in one county
  3. Interpreter services need has to be discussed
  4. Security issues
  5. Look at Regional Schools that closed to determine if therapists are available
  6. Need Task Force to deal with the reality of the statewide EI system
  7. Need to negotiate training if therapist is not available to receive training by the deadline.
  8. Include the program in plan development
  9. Need to revisit the interdisciplinary model
  10. What is the relationship of the NPA to home visits vs day care
  11. Service Coordination and providers need to collaborate and receive training together; not separately.