With Friday’s announcement from FSSA, freezing OASIS allocations until further notice, there has been a lot of cheering and celebrating from consumers and providers alike. I must admit that I reacted in much the same way. We all must realize, however, that this is the beginning of the process, not the result.

I am still fully convinced that, even without an official requirement, uniform rates are a necessary component of any well-run system. I have no doubt that, whatever changes are made to OASIS, it will include this methodology. The dollar amounts must also be something that is predictable to the state, so that they will know how to budget and how to project expenditures into the future. This predictive system must be based on what is anticipated, however, rather than what is automatically allocated as a maximum amount that could be expended. The latest model is a good example of why this is necessary, as it dramatically increased allocations to people that have no intention of using them. These over-allocations could have been used as a pool for those who have needs beyond what their current allocation will support.

Any new system must also be flexible enough to allow consumers to maintain the supports and services that have been long-term parts of their plan. By submitting their current schedule of services, information on how often they deviate from that schedule, and if there are any preferences or needs that the consumer feels are critical, we can have a better picture of the consumer/family expectations PRIOR to the allocation decision.

Finally, an allocation system must be transparent to avoid the problems and criticisms surrounding the original OASIS model. If there have been errors in assumptions made, providers are more likely to be able to determine where those errors lie, in that they can compare specific individuals to specific assumptions over time.

Beyond that, I really have very little more in the way of ideas. Without knowing what was originally attempted, the necessary parameters, and the assumptions made, any suggestion would come from a position of ignorance. I am sure however, that any provider, consumer, guardian, or advocate would agree with me that we are willing to discuss options and provide feedback to whatever comes next.

 

I was reading a journal the other day, and was struck by a quote defining the term “Change Function.” This was defined by the moment when a perceived crisis is worse than the perceived pain of adoption. How well this relates to organizations that serve people with disabilities! As we are generally caught between the need to innovate and the need for stability, “best practice” tends to fall somewhere in the middle. Our consumers, as well as our employees, tend to be most comfortable with the maintenance of the status quo. Any change is best done slowly, and with great care that it does not undermine service quality by failing to identify an unintended consequence.

Technology is available that can greatly increase the efficiency of provider operations. Electronic documentation, timekeeping, and new models of service are available that are much better and faster for gathering information and using it effectively. Compliance with State and Federal regulations can be assured by building them into the systems themselves. More time can be spent in direct support when less time is devoted to burdensome documentation. Still, in light of this, most providers stay with paper based systems, focus on programming areas that have not changed in decades, and devote very little time to trying new approaches to service. When innovation is critical, providers tend to look for existing models that are newer than the model they currently embrace.

I think the reason for this is two-fold. First, providers have an enormous amount of rules, regulations, laws, and cultural beliefs that must be observed. If an existing system has made it through a few audits, and everyone seems OK with it, there is an enormous perceived risk in changing anything about it. When change is forced (by new regulations or beliefs) there is a tendency to change just the area in question, forcing new information into old models. The other reason to avoid updating systems, especially electronic systems, is that in recent years there have been massive shifts in billing and documentation requirements handed down by the state. There is a lot of risk in purchasing systems at high dollars that may be obsolete within months.

The one unavoidable fact of being a provider in Indiana is that the cost of providing services and the amount of needed service will continue to rise, while the available revenue to pay for it will shrink. We are indeed entering a “Change Function” period. The system must change and grow, and people must be served. It is critical that the State and providers work together to find a solution. Providers want to do the best job they can in meeting the needs of consumers, and the government is responsible for assuring prudent expenditures of taxpayer dollars. I do not see these priorities as being in conflict. The system we are transitioning into right now is clearly broken, and many providers are in danger of closing their doors. Some are responding by demanding a freeze of all change, in favor of the status quo. Others are attempting to negotiate, with little success. Most are just keeping their heads down. Here are the facts as I see them:

  1. The world is changing, and the way providers do business must also change.
  2. Standardized rates are absolutely necessary for a level playing field, and they must cover the expense of providing that service.
  3. Providers really do more about providing services in their field than state officials. This is not meant to be an insult, but a statement of fact. An agency with a 50 year record of quality service will know how to do it better than any administration. Compare and contrast State-run institutions and community-based providers for numerous examples (of both programmatic quality and cost effectiveness).
  4. Any system that adds complexity adds cost. Simplify and excel.
  5. Providers will be able to identify ways to reduce costs if a system is in place long term. Innovation cannot happen is an environment that is always in “beta.”
  6. Providers will need time and capital to purchase and develop systems that are more efficient. This will save money in the long run, and will allow a shift in expenses from overhead to wages for DSP’s.
  7. Providers and the government must work together as partners to make things right. There should be discussions with known quality agencies, not just the largest ones. A positive response from a provider serving 10 counties does not balance a negative from 10 providers serving a single county. Urban and rural providers must both be polled.
  8. State policy and provider expectations should not be reduced to the lowest common denominator. It is a regular event for a rule for all providers to change in response to the bad behavior of a single provider. This stifles innovation. Providers who break the rules should be called on the carpet instead of being buried in an overall environment change. To swipe a phrase from my CEO, “That is eliminating islands of excellence in favor of a sea of mediocrity.”
  9. There are already established service fees that are uniform in Indiana. These are set legislatively and are on the books. This is a good starting place.
  10. Non-profit agency financials are public record. It is a very easy thing to verify that taxpayer dollars are being spent wisely and appropriately. By encouraging for-profit companies to be transparent with state dollars as well, there can be a true grasp of the costs of service provision, and funding mechanisms can be tailored to support them.
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