Budget Question # 35: Can you provide the fiscal impact if the City were to fully fund the Early Intervention Part C program? (Councilwoman Gaskins)

Response: 

Number of Children Served:  384

Number of Children on Waiting List: None Allowed (Per Federal I.D.E.A law)

The implementation and funding of Early Intervention Part C services is a shared responsibility of the Commonwealth and local jurisdictions. The Department of Behavioral Health and Developmental Services (DBHDS) has been designated as the Lead Agency for Part C in Virginia. The Code of Virginia, §§2.2-2264 and 2.2-5300 through 2.2-5308, provides the framework for the Infant & Toddler Connection of Virginia Part C system and charges participating state agencies with the following:

• Establishing a statewide system of early intervention services in accordance with state and federal statutes and regulations.

• Identifying and maximizing coordination of all available public and private resources for early intervention services.

• Developing and implementing formal state interagency agreements that define the financial responsibility and service obligations of each participating agency for early intervention services, establish procedures for resolving disputes, and address any additional matters necessary to ensure collaboration.

• Consulting with the lead agency in the promulgation of regulations to implement the early intervention services system, including developing definitions of eligibility and services.

• Carrying out decisions resulting from the dispute resolution process.

• Providing assistance to localities in the implementation of a comprehensive early intervention services system in accordance with state and federal statutes and regulations.

• Requesting and reviewing data and reports on the implementation of early intervention services from counterpart local agencies.

State Funding

Part C funding is critical to ensure all eligible children and families receive timely and appropriate early intervention supports and services. In recognition of continued growth, annual increases have been allocated since FY 2015, and the General Assembly allocated a total of just over $21 million for FY 2020. Increases of $2.5 million and $3.8 million have been approved for FY 2021 and

FY 2022, respectively. In FY2020, reported expenses for the Part C early intervention system exceeded reported revenue by more than $4.2 million (6%). While there have been these funding increases, early intervention rates set in 2009 no longer cover the cost of providing early intervention services. In addition to impacting the need for additional funds, this discrepancy in cost versus reimbursement is contributing to increasing provider shortages and, therefore, high caseloads and multiple instances of noncompliance with federal requirements.

Twelve local systems requested additional funds totaling $1,751,714 in FY 2020. These requests reflect only those additional funds needed to support the purchase of early intervention services (i.e., no salaried positions or system operation costs were considered). An additional $1,247,818 in FY 2020 state Part C funds allocated by the General Assembly through a caboose bill and a small amount of unallocated state funds ($78,389) were the only additional funds available and addressed about 75% of the identified need. The COVID-19 pandemic has had significant impacts on the Part C early intervention system, including on revenues and expenses. Overall, impacts of and flexibilities, such as telehealth, allowed during the COVID-19 pandemic likely prevented more significant budget shortfalls and lessened the impacts of provider shortages.

Local System Implementation

The parameters for Virginia’s Part C system are established at the state level to ensure implementation of federal Part C regulations. Within these parameters, localities determine how their Part C systems will operate based upon local resources and needs. The DBHDS contracts with forty (40) local lead agencies to facilitate implementation of local early intervention services statewide. Local interagency coordinating councils (LICCs) have been established statewide to advise and assist the local lead agencies. The Council of Coordinators Association (CoCoA) Steering Committee members remain engaged in calling for advocacy for increased funding.

The Alexandria Early Intervention Part C Parent Infant Education (PIE) Program provides assessment, case management and developmental therapy services for children birth to age 3 years utilizing evidence-based practices within the child’s natural environment settings. Services were provided to the 384 children who were eligible in FY 2021. Based on current staffing levels (4.0 Service Coordinators, 1 Intake Coordinator, 1 Early Intervention Provider) this resulted in monthly caseload sizes of 85 children per staff member. While all children were served, this does exceed the best practice maximum of 45 cases.

In order to reduce caseloads to the best practice level, a review of the needed staff and costs would need to be completed. Rough estimates of the required staffing to reduce caseloads and improve timeliness of services could require up to seven (7) additional positions at costs close to $100,000 per position. Staff will prepare a more formal review in preparation for the state and local FY 2024 budget process.

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