I think this Proposed Regulation will significantly benefit the families and the children who are eligible for these service, the providers who do these type of services and the State of Virginia who is invested in these types of services.

This regulation clearly lays out the qualifications for providers and provides a consistent payment structure that supports the Federal requirements of Part C IDEA. It will also help insure that families are treated the same across the Commonwealth.

Virginia has much to be proud of for moving in this progressive direction that will greatly benefit those eligible families and their children and those who support them.

To Whom It May Concern:

RE:  Part C Early Intervention Regulation Changes in Reimbursement

Overall, I feel the changes will benefit families across the Commonwealth of Virginia, service providers, and Part C agencies that coordinate the services.  I do have concern for the amount of financial paperwork the service provider will need to attach to the quarterly cost reporting.  I know that the current way takes time and adding more may make this an unmanageable requirement.  It is unclear whether this requirement is for hospitals or for outpatient rehabilitation clinics such as mine. 

I also wanted to comment on the no reimbursement for travel time.  I know that the new rates are supposed to incorporate the cost of traveling to a patient's home, but for those of us who live in rural areas or large counties, this travel time is an area that becomes a pure cost with no reimbursement for the company.  For example, I send one of my therapists to a home that is 45 minutes away, that is 1 hour and 30 minutes round trip of travel, 30 minutes for the therapy session, for a total of 2 hours of time that I pay that therapist, but am only reimbursed for the 30 minute service time.  I know that there are several providers that have retracted from providing Early Intervention Services for this very reason.  It saddens me that there is a shortage of providers in our area when I think of all the little faces that need our help, we need more providers, not less!  If there could be any consideration of this issue, I think it will ensure that we continue to have qualified providers available to the children that need it the most and at the same time ensure that businesses can continue to keep their Early Intervention/Part C contracts without fear of negative revenue to have such a contract.

Thank you for your consideration,

Amie Teague, MA/CCC-SLP

I feel that what the Part C Early Intervention Services rendered to the areas young children is a positive endeavor to help them secure a better future.  Early Intervention not only identifies children with special needs and coordinates with local professionals to provide services to those children, it also helps the parents and caregivers with resources and tools to enable them to reinforce the services their children receive.

The changes made to the Medicaid/Part C Early Intervention payment system have greatly improved how Medicaid pays services for these patients.  Patients are qualified and registered through Early Intervention Services.  EI Certified Providers need only to document services rendered and bill using the new Medicaid EI Codes.  It would be wonderful if the same type of system could be developed for patients with commercial insurance.

The Early Intervention Part C Services is an excellent program working to improve the lives of the children they provide services to as well as their families and communities.

Upon reading the proposed final regulations for Medicaid Early Intervention Services, I was initially confused as to whether the text was a hyperlink to another website (text is underlined).  The text of the document was easier to follow toward the end of the regulations.

I felt that the concepts of Early Intervention were clearly explained and defined as per the Virginia state requirements.  This would be a good document to have on file to give to parents who are new to the system or have questions about staff roles. 

Federal law allows states to include the services of a variety of licensed health care practitioners in their State Plan coverages. The services of the most common practitioners are addressed through tables specific to them, i.e., podiatrists, chiropractors, optometrists, psychologists and certified registered nurse anesthetists. However, there are other practitioners whose services are covered and directly reimbursed in selected states. Such practitioners include physician assistants, nutritionists, dieticians, dental hygienists, acupuncturists, mechanotherapists, naturopaths, respiratory therapists, pharmacists, medical social workers, behavioral health practitioners and counselors, pastoral counselors, marriage and family therapists, and sign and other language interpreters. States that include these services generally establish copayment and prior approval requirements as well as coverage limitations consistent with other similar services.

Regards,

James Nelson

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