Date: February 25, 2025
From: Lenita Hartman, Acting Early Intervention Program Manager Christy Scott, Interim Director, Division of Community and Family Support
Re: Early Intervention Emergency Cost Containment Measures Effective March 3, 2025
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Background
In June 2020, a rule change was implemented which narrowed the eligibility criteria for the Early Intervention (EI) program in response to budget balancing needs of the state as a result of the pandemic. This led to a decline in monthly average caseloads.
Effective January 1, 2023, the eligibility definition for the EI program was again changed, this time to broaden the eligibility to serve more children in the program. The full impact of this change will not be realized until January 2026. Increasing the caseload for the EI program raised concerns about the capacity of the EI workforce to serve the additional children.
The EI program had $4 million in funding available in FY 22-23 which was distributed in two rounds of bonus payments to EI Broker staff and subcontracted providers who work directly with children and families. Additionally, $3.5 million in state funding was made available for FY 23-24 and FY 24-25 to address the recruitment and retention of the EI workforce, and recommendations were implemented due to the availability of this funding. The ability to sustain these recommendations was dependent upon the ongoing appropriation of this funding.
Current Situation
The $3.5 million workforce investment funding, which was allocated for two years, will end June 30, 2025. Referrals to the program continue to increase and stimulus funding that was previously available has fallen off, which impacted the amount of federal funding the EI program had available for FY 24-25. Additionally, the number of children enrolled in Medicaid has decreased to around 36%. These factors, along with the implementation of multiple strategies to retain and recruit the EI provider workforce, have put the EI program at risk of significant over expenditure for the current fiscal year and a significant reduction in resources for FY 25-26 and beyond. Because of this, cost-containment strategies are necessary.
The EI program and CDEC are working diligently to protect: ● The current eligibility criteria for children referred to the program ● Provider rates there is no plan to reduce subcontracted provider rates ● Service coordinator caseloads
● The implementation of TEAM EI Colorado, beginning July 1, 2025, which is a primary provider/teaming model of service delivery and was identified by the EI Workforce Investment Committee as a high priority.
Action Needed/Emergency Response Measures:
The EI program will be implementing several cost-containment measures to assist in balancing the budget for FY 24-25.
Effective March 3, 2025, the following changes will occur:
● Suspension of the: ○ Reimbursement of subcontracted providers for scheduled visits or an Individualized Family Service Plan (IFSP) meeting where the family cancels or does not show less than 24 hours from the scheduled visit. This does not include Evaluation Entities as payment for the percentage of no-shows is a contractual obligation; ○ Compensation of new providers for completing the required 15-hour Initial EI Provider Training and the follow-up training stipend for completing a survey after 6 months; and, ○ The $30 stipend for subcontracted providers that are billing Medicaid for a speech and/or language session to help support the monitoring of IFSP outcomes. ● The EI program was unable to implement a statewide mileage and travel policy for subcontracted providers, therefore, mileage and/or travel will no longer be paid to subcontracted providers in any circumstance to ensure equity across the state. ● Children enrolled in the EI program and also enrolled in Medicaid must be provided a service that is eligible for payment through Medicaid (OT, PT, SLP). This applies to any child enrolled in Medicaid regardless of whether the service is provided by a subcontracted provider or a provider employed by an EI Broker. The EI program will continue to support local communities to provide services to children impacted by this change via telehealth and assistance in identifying providers who are enrolled with Medicaid. Individual consultation will be provided to communities in more difficult circumstances. ● All children enrolled in the EI program will have their IFSPs updated to reflect a maximum of 16 (15 minute) units per month. For children where less than 16 units were identified to address the outcomes on their IFSP, additional services may not be added. A primary provider approach to service delivery may be implemented within communities that have already completed applicable training. ● Children who have a third birthday on May 1, 2025, or later (Extended Part C) will have IFSPs that reflect the need for 4 units of service each month until the beginning of preschool special education in the fall. ● Beginning April 1, 2025, any child newly eligible for the EI program will have services begin no earlier than 28 days from the date the parent signed consent.
● Funding for EI Evaluation Entities to complete evaluations is expected to be adequate for the remainder of FY 24-25, however, if an EI Evaluation Entity experiences higher than anticipated referrals and overflow evaluation options are not available, new evaluations may need to be delayed until the beginning of FY 25-26. Required federal timelines are not expected to be impacted.
These strategies will continue into FY 25-26. Additional strategies for longer term cost containment are planned for FY 25-26, and will be shared over the course of the next few months.
The EI Colorado state team is working hard to determine the best way to support families, EI Brokers, providers, and EI Evaluation Entities with these difficult changes and will make every effort to answer questions and work to find solutions. Initial meetings were held with the Alliance of Colorado Policy Group on February 20th and the broader Alliance and EI Broker Leadership on February 24th to review these new requirements.
Upcoming webinar sessions have been scheduled to communicate this information across the EI Community including:
● February 26th and 27th for EI Providers, EI Broker staff, and EI Evaluation Entities. ● March 4th and 5th Family Information Sessions
Further communication and guidance to assist in implementing these changes will be distributed by February 28, 2025. Questions or suggestions may be shared here. For additional information please contact Lenita Hartman at Lenita.Hartman@state.co.us or call EI Colorado at 1-888-777-4041.