Pa loophole sample letter

[Guest guest]

Hello all from Pa,

Just thought that I would pas along a sample letter for the

waiver/co-pay thing.

Joe

+++++++++++++++++++++++++++++++++++++++++++++++++++++++++++

Department of Public Welfare,

Office of Income Maintenance,

J. Zogby, Director,

Bureau of Policy, Room 431 Health and Welfare Building,

burg, PA 17120,

(717) 787-4081.

RE: 1115 Demonstration Waiver for Medicaid for Children with

Special Needs [35 Pa.B. 4676]

Hello Mr. Zogby,

I find it incredible how muddled and wrongheaded the thinking

is to charge a co-pay to families who make more then 40K/year

and have children on social security disability. This assault

on the middle class families of Pennsylvania is more than

unfortunate in that it discourages work. The truth is that

Pennsylvania pays for the disabled children in these families

so that it does not have to tackle the more serious and

politically inflammatory issue of behavioral health parity

legislation. The governors basic fear is that to stand

against the insurance companies would flow thousand of

dollars into his opponents coffers. So it is just easier to

dump the burden on working families. It is odd that no-one is

entertaining the idea that even the co-pay should be pick-up

by the insurance companies. This is truly sad. Sadder is that

the budgetary difference of this proposal for the state is

miniscule totaling an estimated 11 million dollars.

1. Help local school districts develop cyber classrooms. If

this can be done, then the largest trigger for children’s

emotional problems in school things like fellow student

teasing, fighting between students and other social stressors

will be eliminated. If a mere 10% of Pennsylvania’s ES

students move into cyber-charters, schools would be safer and

their would be no need for expensive consultants to help

manage the children’s behavior in the classroom as well as

all the money saved on TSS workers.

2. One of the most serious issues in these community and

school based programs is the lack of oversight. This lack of

oversight leads to waste. Improve oversight of programs and

eliminate waste, fraud, and abuse. Even if abuse is only .5%

this totals over 3 million dollars that can be returned to

the budget.

3. In addition, the system is overrun with personnel whose

training is not clinical in any sense and thus the quality of

care that they provide is questionable at best. On parent

told me that her last behavior specialist had a master’s

degree in English. I fear the only behavior that he was

specializing in was fraud. He would hand her a sheet of paper

to sign, dump some advice like she should talk more to the

child, then tell the child “listen to your mother†and

leave. Often special education teachers are conducting BSC

or MT work. Make sure that all staff members in BHRS have had

at least five clinical courses and an internship.

4. Stop funding the growth of bureaucracies under the heading

of “continuum of care.†The research shows that these

monstrosities are less efficient and deliver no better

services. A better strategy would be to contract directly

with licensed master level providers (LPC, LCSW, MFT). The

master level practitioner has little overhead. This would

allow for the freezing of rates. The federal insurance Tri-

Care contracts directly with board certified behavior

analysts to perform services to children with autism and thus

eliminates the “middleman.†Direct contracting will also

help the department to reach more rural areas. New Jersey

contacts directly with master level providers and has been

quite successful in keeping costs low. In the current

situation the administrative overhead is doubled because both

the providers and the managed care companies are responsible

to have a continuum of care. Making the managed care company

hold the continuum of care and not the provider removes the

duplicated administrative overhead and reduces duplicated

overhead.

5. For children with oppositional defiant disorder mandate 16

weeks of behavioral parent training (a well established

evidenced based practice) groups before the use of more

restrictive and costly services such as family based and wrap

around services. Such groups should be run by master level

personnel who have considerable qualifications in behavior

analysis/modification. Possibly board certified or associate

level board certification in behavior analysis. If even 10%

of the families who would go into BHRS or family based

services are differed then the savings would be millions.

6. Use family based prior to wrap around. Prevention programs

targeted to children at risk and behavioral consultation to

head start to intervene early. Establishing Blue Ribbon

commissions to ensure that research based practices are used

with high treatment integrity will save money.

7. Encourage providers to reach out to the nurse practioner

and physician assistance programs. Speak to students in these

programs. Hiring nurse practioners and physician assistants

to reduce the need for psychiatrists and reduce costs.

8. Only use Behavior specialist consultant’s who are board

certified in behavior analysis. This will ensure competence

in creating behavioral programs, so that the programs do not

go on indefinitely.

9. Clearly define medical necessity and link it back to

behavioral health. It seems like OMHSAS has become the

department of bad behavior. Every time a child has a

behavioral issue, people want to prescribe 30 hours of TSS.

10. Change the provider culture from one of mediocrity to one

of excellence. Change the culture of OMR to one with a focus

on providing evidenced based MR services (consultation to

parents on habilitation and improving communication skills,

improved training for classroom management for teachers,

etc.) so that MR children are not overwhelming the MH system.

It is estimated that 30% of children in Philadelphia’s BHRS

program have co-occurring MR diagnosis.

11. Develop critical therapeutic foster homes and teaching

family homes- two evidence based practices that reduce

delinquency and are successful for children with emotional

and behavioral disorders. These will create cheaper

alternatives to residential treatment, while helping children

stay with caring family oriented adults.

Thank you,