Bureau of Early Intervention
Empire State Plaza
Corning Tower, Room 287
Albany, NY 12237-0660
February 14, 2013
Dear Mr. Hutton:
I am in receipt of the recent email announcement regarding cut off dates for transfer of responsibility for early intervention billing from the Counties to the State that will be effective 4/1/13.
There is a concerning lack of information in this email given that there will be significant changes to the billing systems in the very near future. In fact, I have not even received any kind of contract from NY State that will outline the new relationship that will begin in just 45 days.
Most importantly, the email states that information about billing methodology will be sent to providers in mid-March. That will leave only two weeks' notice to interpret the guidelines and to develop systems for billing.
I am an agency provider and I employ several therapists who work in the Early Intervention Program. Payment delays are already routine and planned for given the known reimbursement cycle from the Counties. The unknown billing system that will be implemented in 45 days by the State and unknown reimbursement cycle is a severe threat to the employment of many people who work for the Early Intervention Program.
I suspect that larger agency providers will be able to absorb the uncertainty of these times, but as you are aware, a very large number of small agency and individual providers are under threat. No one can operate a small business under a situation where the billing methodology is unknown and the reimbursement cycle is unknown.
This lack of functional communication to the providers who serve the Early Intervention Program can place the system in jeopardy. Even if large agencies are able to absorb payment delays it is unlikely that they will hire up all of the smaller providers who have to leave the system. Shortages of providers is a real potential problem.
Early intervention is just a fractional portion of my private practice, but I am concerned that it may soon be an even smaller portion because quite frankly I don't know how I am supposed to provide services to a program that seems to be taking steps to purposefully implode. This has all the appearances of a planned demolition.
If it is not the government's intention to purposefully implode this program, I suggest delaying implementation of a new billing system and providing at least a 2 month window so providers can plan for and implement the new billing processes and plan for a possibly new reimbursement cycle. I am not fighting the changes, sir; I am only interested in having a reasonable notice period so I can actually review the pending contract and figure out how the new relationship will pragmatically work. I want to continue employing people who will work under your program. Will NY State allow this?
The provider community for the Early Intervention Program has been patiently waiting for guidance. Two weeks' notice is unreasonable.
Christopher J. Alterio, Dr.OT, OTR
Owner, ABC Therapeutics