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Address
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Understanding the Impact of the Early Intervention
Rate Reimbursement Reduction on
Early Intervention Independent Contractors
Date
Dear
As you may be aware, on April 1st of this year, the Department of Health
Commissioner, Dr. Richard Daines reduced the reimbursement rate of Early
Intervention Independent Contractors session by 10%. This cut was also paired
with an increase in the rate of group sessions provided by agencies by 42% and
an increase in Service Coordination rate by 4%. Early Intervention programs
immediately enacted this change.
Many passed on the entire cut to
providers/independent contractors.
Additionally, the majorities of Early
Intervention administrators have passed this reimbursement rate reduction not as
a 10% decrease but in some cases as high as 20% --to the exclusion of any
other programmatic changes or pay decrease of staff or administration. Are
there not more equitable means of reducing costs? I would like to take this
time to explain to you what exactly is factored into our per session rate.
First, I would like to describe to you what our overhead costs consist of.
As independent contractors we are responsible for our own health insurance,
disability insurance, malpractice insurance and the funding of our own retirement.
We also need to pay for the renewal of our NYS License, our yearly membership
dues to national associations and continuing education (required by our licensing
bureaus) which includes e.g. attending conferences so that we may continue to
practice in our chosen field. Since we travel to each client using our personal
vehicle, we are responsible for paying for the gas, auto insurance, and
maintenance of our vehicles. Personally, I put on at least XXX work miles per
month. Other therapists that work in the more rural areas put on more miles and
have more drive time between clients. We are also required to carry additional
automobile insurance than the average driver to secure our contracts with the
counties at increased cost. Also included in our expenses are the therapy
equipment/supplies: toys, books, materials, office supplies, postage and copy
and fax machines we need to conduct our sessions and run our practice. We
also pay for our own standardized assessment tools and forms (required by the
state) which we use to monitor progress and conduct initial evaluations. These
tests often cost in excess of $300 and are updated regularly and, therefore, new
tools must be purchased on a regular basis. Lastly, since we are self-employed,
we all pay self-employment tax.
Also seemingly “factored in” to our session rate are tasks required to
perform our function. That is, travel time between clients, progress note writing,
report writing and billing, daily session planning, toy washing, attend mandatory
trainings, and attendance at meetings regularly to discuss the need for continuing
services. All of these activities are done on our own time outside of session time.
We also undergo audits every three years conducted by IPRO.
As independent contractors, we also work more hours than those
employed by agencies. We typically stay at our sessions for at least 15 minutes
longer than the prescribed mandates, whereas agencies require their staff to
maintain 50 sessions per week or 10 sessions per day at half-hour intervals.
Although Early Intervention is a 24/7 and 12 month program, most agencies
follow a school year calendar making it an option for therapists to see Early
Intervention children during school breaks. For many Independent Contractors,
working for an agency is not an attractive option. The cut that the agency
owner takes is significant, making for a salary that is not a livable wage.
Additionally, Early Intervention employees of agencies do not have the
opportunity to work directly with families, train families, or communicate regularly
with families.
What has made this recent decrease in our pay especially frustrating is
that not only did our rate decrease by 10% in April, we have only seen one rate
increase in the amount of $2.00 a session in September of 2003 and we were
reimbursed retroactively from December 1, 2002 - August 31, 2003. (Additionally
several counties inclusive of Nassau and Westchester, experienced an increase
in session time without an associated increase in reimbursement rate). That is,
e.g. (Albany County) since 1993 our rate has increased from $67.00 a session to
$69.00 a session and now decreased to $62.00 per session. Therefore, we are
earning less than we were earning in 1993. As I am sure you are aware, none of
the expenses that I have described have been reduced over these same years.
As a matter of fact, according to the NYS Data Center, the consumer price
index from 1993-2010 has realized a 55.37% increase in the cost of living.
As Early Intervention independent contractors, WE face the children and
their parents, WE push progress, WE are the front line, the most productive
members of the New York Early Intervention Program Team. WE are the
change agents. Why were we unfairly targeted? Because we are not
organized? Because our fields are overwhelmingly female rather than
male? Because we are kind, compliant, giving, empathic individuals?
The American Recovery and Reinvestment Act of 2009 (ARRA) stimulus was
intended to create jobs, promote investment and consumer spending during the
recession. The Act includes federal tax incentives for domestic spending in
education, and health care. DOH actions have been counter to the intent of the
ARRA. Additionally, new DOH regulatory guidelines have effectively closed our
small business many of which are run by women. Is this the intent of ARRA?
It is our hope you will support our position and help women (and men) in small
businesses be treated fairly and not be forced out of business.
I look forward to a resolution that will benefit all those involved in Early
Intervention. I welcome the opportunity to meet with you to discuss this matter
further. I will be contacting your office to set up a meeting.
Sincerely,