There is a proposed change within the EI State Plan Amendment that would create two separate fixed rates for ISC with billing related time requirements that we predict most counties would not meet. We are concerned that this could have a fiscal impact to counties, so we plan to reach out to BEI this week for clarity. This proposed change is currently sitting with CMS for final approval. Attached is the State Plan Amendment with attention to pages 24 (Method of Reimbursement) and 27 (change in payment methodology), as well as a list of questions that NYSACHO will bring forth to The Bureau of Early Intervention.

Where would Putnam ‘fall’ on the Fee Schedule o Page 25?

See attachment.

See attachment.

There is also a separate fixed rate of OSC (in addition to the two fixed ISC rates), not sure if you wanted to clarify that.  Also, page 25 is the page which outlines the change in payment methodology, not page 27.

Most times we would meet the time requirements of 2 or 3 hours for initial Service Coordination, and the proposed rates for those time requirements are a bit higher than what we currently are able to bill for. My concern is that we would seldom meet the 1.25 hours per child per month. A big question is going to be what happens if we only have 60 minutes of service coordination for a month. Right now we would receive $56 for that service coordination, under the new plan we may not receive anything for that month (the minimum in the regs says 1.25/hrs per month) Most times the monthly contact is a phone call or two lasting only minutes. Exception is if there is an IFSP meeting which occurs every six months for each child, those meetings usually last anywhere from 30-90 minutes. If the regional rates are adopted/approved, will this impact the EI Admin Grant dollars to counties? In the Method of Reimbursement attachment states that Providers will be allowed to bill in quarter hour units. Does this mean that if the minimum amount of time dictated is not met then provider can bill for the time provided in quarter units? If so, how is that any different than how we bill now which is in quarter units?

After reading the Method of Reimbursement it states that “In the instance that the minimum base rate is lower than the regional average, the regional average will be used for the calculation of all three rates [Providers will be allowed to bill in the quarter hour units]. Does this mean if the minimum base time is not met then we would just bill in the ¼ hour increments we do now? Have they increased this ¼ hour reimbursement rate at all? This then provides no increase in reimbursement for service coordination services and this whole long process of updating the rates has really been pointless. I agree with all of the questions asked and we definitely need clarification of what can be considered in the minimum base time such as travel, paper work etc.
If we met the minimum base rate in our area for the monthly OSC, which is the best I can tell “Western Rural”, we would get $74.00 vs the current $70 we get by ¼ hour billing. This is NOT going to incentivize any of our outside agencies make to provide service coordination.