Dear Commissioner Velez:
I am writing today on behalf of the members of The Alliance for the Betterment of Citizens with Disabilities (ABCD). As you know, ABCD is a statewide organization representing member agencies that provide an array of community –based supports for more than 15,000 people with complex physical and neurological developmental disabilities and their families. We would like to ask for your deliberate consideration of our requests as you and your colleagues at the Department of Human Services and the Division of Developmental Disabilities prepare your budget for State Fiscal Year 2016. This continues to be a very important time for the DHS/DDD service delivery system. Now, more than ever, thousands of individuals with disabilities and their families, as well as the citizens of the state are counting on all of us involved in the support system to get it right. Collaboration and partnering is as essential as it has ever been.
We present the following requests for your consideration, confident that the Department, indeed Governor Christie’s administration, remains committed to reinvest savings from closing developmental centers and new revenue from the implementation of the Comprehensive Waiver in the development of the community support system infrastructure. We urge you to reaffirm this commitment as we move forward.
As the implementation of the Fee For Service contracting with Medicaid and the standing up of the Support Program portion of the 1115 come closer to reality as Fiscal Year 2016 opens, there are still some very important issues that need to be addressed. Providers of community –based supports and services, your partners in providing opportunities for individuals with intellectual and developmental disabilities to pursue their hopes and dreams by actively participating in inclusionary communities, face increased financial pressures to maintain quality programs that are fiscally stable. We ask that as you prepare your 2016 budget that you not only maintain the status quo, but include additional funds to enable your partners to insure quality supports while devoting resources to re- engineering their operations to meet the demands of the future.
Providers are being asked to maintain quality services and supports AND expend valuable resources to re-engineer their billing systems, record systems and data systems. A Fee for Service model requires new ways of doing business, new skill sets for many employees, new software and hardware. The constitutional amendment to increase the minimum wage annually and the requirements of the Affordable Care Act present yet additional challenges to providers. Many providers do not have access to capital to make the necessary investments in these resources when they have not received any increases for 7 years on cost based contracts. Some providers may have been able to raise philanthropic gifts to cover their operations in the past, but there is only so much philanthropic dollars available; raising money is not getting any easier. Finally, without the guarantee of state backed contracts, providers will not have much in the way of assuring banks and other lenders that they are sustainable entities worthy of credit.
Therefore, ABCD would like to ask that DHS/DDD include four measures in the State FY 2016 budget:
At the point of implementation of Fee For Service contracting allow for a “Bridge Funding” process for FY 2016, in which the state continue to pay providers their state contracted rates for up to 12 months while, simultaneously the providers start to bill Medicaid directly. The providers will maintain billing records that will be reconciled at the end of the period during which they could “double bill” and would pay the state back the difference between the contracted rates and the Medicaid receipts. This “Bridge Funding” was used in 2000 when the state Department of Children and Families and in 2010 when the Department of Health moved Early Intervention services to fee for service environments.
The advantage to the state is that they insure continuity of supports and services for individuals with intellectual and developmental disabilities and their families from the partners with whom they have contracted for decades. There is no additional money required long term. The state is made whole within one fiscal year.
The advantage to the providers is that they maintain cash flow in a period when they are most vulnerable to glitches in the Medicaid system. Even in the best of scenarios, we must expect that everything will not go perfectly. This process guards against missteps that could wreak havoc on the delivery system. Furthermore, providers will be given an opportunity to begin to establish cash reserves that will guard against future unexpected expenses, provide collateral for bank loans, and support service delivery expansion. Service delivery expansion will be required as the state begins to provide services and supports to those currently on waiting lists.
We are also requesting inclusion of $5 Million in the budget to be designated to infrastructure costs incurred by providers in the switch to Fee for Service. This is a one-time budget expense that would give each provider in NJ approximately $25,000 for expenses directly attributable to the switch from contracts to direct billing of Medicaid. As indicated above, providers are being asked to maintain quality services and supports AND expend valuable resources to re-engineer their billing systems, record systems and data systems. A Fee for Service model requires new ways of doing business, new skill sets for many employees, new software and hardware. This request would allow many providers to maintain sustainability during this critical period.
We request a $13 Million budget item to pay for services to 330 individuals in the Priority Category of the State Community waiting List. The Priority Category has grown to 3,700 people. Now that two State developmental Centers have closed, we need to provide supports and services to those in the Priority Category! As you well know, those in the Priority Category are there because they are deemed to be close to emergency status. It would be well if we could begin to preclude them from having to experience an emergent tragedy before they can secure services.
Finally, we are asking for a designation of $3 Million for Housing Vouchers for 300 individuals with Intellectual and Developmental Disabilities. This would provide necessary support for 300 individuals who are in desperate need of housing. As service delivery and housing are more and more separated, the housing needs of individuals become more critical. As you are aware, more and more individuals and families want to keep their children in the community and dream of inclusion in their local communities. We believe that this request will enhance our ability to attain the dream and promise of CMS’s Community Rule.
We thank you for the opportunity to share these thoughts with you. As you know we are in the process of setting up a meeting with you in early January to discuss these items with our colleagues from the Arc of NJ and NJACP. I look forward to that opporetunity for dialogue. ABCD members look forward to actively participating in the creation of a new and improved service delivery system with DHS and DDD.
Daniel J. Keating PhD