Virginia Regulatory Town Hall
Agency
Department of Behavioral Health and Developmental Services
 
Board
State Board of Behavioral Health and Developmental Services
 
chapter
Requirements for Virginia's Early Intervention System [12 VAC 35 ‑ 225]
Action Promulgate 12 VAC 35-225 on Early Intervention Services System & Repeal 12 VAC 35-220
Stage Emergency/NOIRA
Comment Period Ended on 2/11/2015
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2 comments

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1/19/15  9:43 am
Commenter: Mary Ellen Plitt

Support for increased funding for Part C early intervention services
 

I would like to communicate my support for the following amendments to the budget:

  1. $500,000 for FY15 to mitigate anticipated deficits
  2. $1,188,205 SGF in FY16 to increase the Medicaid Early Intervention Targeted Case Management Rate from $132 to $175
  3. $2,054,592 SGF in FY16 to accommodate growth

Part C early intervention services are crucial to families of infants and toddlers in need of supports and services to increase participation in their homes and communities and to enhance future success.  Early intervention services are cost-effective, family-centered and evidenced-based. As need for e.i. services are increasing, it is essential to ensure that these families will have access to them.

Thank you for your consideration.

 

Mary Ellen Plitt

CommentID: 37456
 

2/11/15  11:52 am
Commenter: Jan D. Jessee, Professional Therapies, Inc.

Support for Increasing EI Funding and Medicaid Rates
 

As a Certified Rehabilitation Agency since 1984 and as a Certified Early Intervention Provider since 2009 (when Certification began), Professional Therapies, Inc. has been pleased to provide therapy services (physical and occupational therapy and speech/ language pathology services) in the Early Intervention System.We have provided these services since 1986, before the reorganization of the State System.We participated in the cost study commissioned by the State in 2004. We also have volunteered much time and effort for the Infrastructure Transformation Task Force and other commitees at the State level.

The Cost Study found that the cost for providing an hour of direct therapy service was $167.86 as of 3/1/2008. Since transition to a Statewide payment system as of October 1, 2009, therapy professionals have been reimbursed at a rate of $150.00 per direct service hour ( 10.6% below the cost determined by the State commissioned study in 2008). During the study period, Solutions, Inc. found that personnel costs were increasing at a rate of  6% per year between 2003 and 2007. If that 6% is used, then the cost to Providers for one hour of therapy would now be $252.40!! Realizing that the System cannot bear such an expense at this time and projecting a minimal 1.5% increase per year since 2008, Providers should now be paid $186.29 per service hour just to keep up with minimal cost increases.However, NO increase has been given to EI Professionals since October, 2009. The EI Professional rate needs to be raised to, at least, $170.00 per service hour just to maintain the substantial below cost reimbursement rate first established.

We, therefore, respectfully request that the EI Professional rate (as the State terms it) be incresed to a modest $170.00 per hour. We understand and agree that, as the previous commenter, Ms Plitt, and the December 1, 2014 DBHDS Report to the General Assembly reflects that the Case Management rate paid by Medicaid still falls short of the cost to provide those services.The plight of the EI Professionals has not been discussed in any of the reports. In most cases, case management services are provided by public providers while therapy services are provided mostly by private providers with no other funding sources. Additionally, the Medicaid case management rate was increased by 10% in 2012 whereas, NO increase has been given to the Professional rate.

Based on service provision numbers provided in the General Assembly Report and taking into consideration both the directly reported PT, OT, and ST service expenditures plus the aggregated reported amount expended by private providers for therapy services, this $20.00 per hour increase would amount to $4.1 Million statewide. At least 50% of this would be born by Medicaid and, therefore, the total State expenditure would be further reduced by more than $ 1 Million because of federal matching funds.

These Services are very valuable to these infants, toddlers, families, and caregivers and need to be funded appropriately so that Providers can continue to provide family-centered quality services.

Thank you for your consideration. We would be more than pleased to provide any further information you may need regarding this statement.

Jan D. Jessee

CommentID: 39045