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