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Tag Archives: Part C

The Texas Department of Assistive and Rehabilitative Services (DARS) has released their Legislative Appropriations Request (LAR). The full document can be found here: http://www.dars.state.tx.us/reports/lar2016_2017.pdf . This document represents the agency’s budget request for fiscal years 2016 and 2017 (taken together these are a biennium). This is the first step in the budget process, where the agency identifies what it needs and what special requests that it has. This will be matched in the beginning of the Legislative session in the spring of 2015 with a document by the Legislative Budget Board, which will be their view of what the agency needs. The agency will then spend the spring testifying before the Texas Legislature to secure its appropriations.

This is an extremely important document because there may very well be more significant changes on the horizon for the Early Childhood Intervention (ECI) program. Reading through the document, DARS tells us that in fiscal year (FY) 2013, ECI served approximately 25,000 children per month. In their LAR, they are projecting to serve a little over 22,800 by FY2017. This represents an almost 9 percent decrease. During this time, the average monthly number of hours of service per child per month is projected to increase from 2.61 hours/month to 2.93.

In their LAR, DARS is projecting that ECI will essentially maintain its budget in FY 2016, but will see a reduction of more than 15% during FY2017. In other words, in their baseline budget request DARS is telling us that they are projecting a decrease in funding and are projecting that they will need to serve fewer Texans between the ages of birth and three years old.

As a result of this, DARS is making two special requests for funding in their LAR on behalf of the ECI program. The first is a request of over $25,000,000 over the biennium just to maintain the projected FY2015 case levels. From page 189 of the LAR: “Federal IDEA Part C funding available to fund the ECI system in Texas has remained flat in recent history. However, ECI program costs associated with federal
requirements and not reimbursed by Medicaid has resulted in the agency using more federal IDEA Part C funding for allowable program expenses than projected. As DARS uses more IDEA Part C funding in fiscal years 2014-2016 to support ECI program costs, the result is less IDEA Part C funding available to maintain base funding levels and serve eligible children in fiscal year 2017. Funding for this exceptional item is to maintain the number of children served in fiscal year 2016 in fiscal year 2017 in the ECI
program.”

What does this mean? It means that Texas has consistently underfunded the ECI program, relying on a finite amount of Federal funding instead. That funding is running out, creating a shortfall. If that shortfall is not covered, Texas will have to provide ECI services to fewer children.

The second special request is an additional $25,000,000 over the biennium to increase monthly caseload to over 30,000 by FY2017. DARS is projecting that even with their more stringent eligibility criteria the number of young Texans who qualify for ECI is going to increase pretty dramatically by FY17.

My take on the bottom line, DARS needs an almost fifty million additional dollars over the biennium to continue to offer services to young Texans who qualify under the current eligibility criteria. If they can’t get that through the Legislature, there will be another difficult round of system changes that involve a combination of more stringent eligibility criteria (so fewer children are being served) combined with more family cost share.

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In previous postings I have discussed issues that have arisen as a result of funding constraints for Early Childhood Intervention (ECI) in Texas.  As a result of funding constraints, the state agency that oversees ECI (Department of Assistive and Rehabilitative Services, DARS) had to make changes to ECI which included:

  • Narrowing the eligibility of who qualifies for ECI
  • Implementing a family cost share so that parents pay for some of the services
  • Requiring ECI providers to directly bill Medicaid for reimbursement

 

These changes had unintended consequences.  Because eligibility was narrowed, it resulted in the children being admitted to the program needing greater services.  This means that ultimately as the population increases, the program will have to be narrowed even further (if funding remains static) due to this.

 

Texas is not the only state experiencing challenges with providing ECI to children and infants.  The IDEA Infant and Toddler Coordinators Association (www.ideainfanttoddler.org) does an annual survey of IDEA Part C (i.e. ECI) coordinators about implementation issues and challenges.   The 2011 survey is located here: www.ideainfanttoddler.org/pdf/2011_State_Challenges.pdf .  The survey results are sobering.

 

I’ll look at this report dealing with several matters:

  • Eligibility for ECI
  • Service delivery
  • Fiscal matters
  • Participation in Part C

 

Eligibility:

Texas narrowed the eligibility of infants and toddlers who qualify for ECI, as a result fewer children are admitted into ECI.  Of the 50 states and 3 territories surveyed:

  • 20 states require one of the following for eligibility for ECI: at least 25% delayed in two or more domains, 30% delay in one or more domains, 33% delay in one domain, 1.3 standard deviations in two domains, 1.5 standard deviations in one domain
  • 18 states require one of the following for eligibility for ECI: 40% delay in one domain, 50% delay in one domain, 1.5 standard deviations in two or more domains, 1.75 standard deviations in one domain, 2 standard deviations in one domain, 2 standard deviations in two or more domains.

 

In other words, 38 states are more restrictive than Texas in terms of eligibility criteria.  In addition, ten states made their eligibility criteria more restrictive over the last three years.  One made theirs broader.  Ten are changing their criteria this year.

 

Service Delivery:

Looking at all states, the number of direct services hours that were delivered, per child per month, has declined by approximately 22% from 2009 to 2011.  In 2011, the nationwide median for number of hours of delivered services, per child, per month, was 4.5 hours.

 

Fiscal Matters:

As a result of funding challenges:

  • 8 states have implemented family cost shares or increased those fees
  • 9 states have required the use of private insurance for ECI
  • 9 states have narrowed eligibility
  • 8 states have required prior approval when service hours exceed a specific amount
  • 13 states have reduced ECI provider reimbursement

 

21 states have conducted some type of study or planning process as a result of the fiscal situation.

 

In other words, like Texas, a lot of states are experiencing funding challenges with ECI.

 

Participation in Part C:

Worryingly, according to this survey, eight states are discussing or planning dropping out of Part C.  Most of this is due to the cost of the program and population growth (i.e. it’s not a sustainable program).

 

It’s a sobering look at the rest of the country and hopefully provides some perspective on what is happening in Texas currently.