OK, first of all, my purpose in adding this post is not to cut off commentary in the post below. Feel free to read and comment on either (or neither.) But I am in the mood to expand on my own snarky comment regarding socialism. Here is the first of some ideas I would have added to the DDS report had it been my honor to write it. This will be the first in a series of one or more proposals to control regional center costs and improve service through deregulation.
Eliminate vendor codes: Whatever the intention of the vendor codes, the principle functional purpose they rightly serve is to limit the breadth of service a single provider can offer, lowering the quality of the services vendors provide. The (likely) unintended function is to foster service denials by implying, at least sometimes, false redundancies. This reduces the flexibility of Regional Centers. A tertiary function of the service code is to waste regional center operations budgets on distractive, unproductive idiocies which then discredit the notion that non-profit boards provide guidance.
Finally, vendor codes probably add administrative costs needlessly by requiring different needs to be met under separate administrative arrangements. For example, if a person receives job-coaching but also needs help budgeting, cleaning their apartment and socializing, that person will generally be helped by three different agencies or at least three separate divisions of one agency with separate staff for the employment assistance, living skills and social assistance. This means the state pays for the liability insurance three times, the administration three times and the training and recruitment three times at the vendor side and the quality assurance three times, the service coordination three times and the billing three times on the regional center side. (Plus all the
unproductive time spent by core staff at regional centers trying to cleverly craft changes to the purchase of service policies and get them rubber-stamped by glassy-eyed board members.) Meanwhile, the client gets possibly triple the number of people to work with and is at risk that some need will not be met due to limitations placed on the vendor categories.
The vendor codes help the regulations to address specific service designs that address specific needs specifically but there are two reasons this might not actually be helpful. First, if you read the service standards portion of the California Welfare and Institutions Code, Title XVII - Division 2, Chapter 3 which defines the service codes and cross out all the regulations that are not typically monitored or enforced, too vague to provide clear guidance or that essentially self-repeal (cf section 56742 (a)(3-4)) you might easily be left with nothing but paragraph numbers and the vendor codes themselves anyway. The second reason this might not be important is that it is a fundamentally agency-centered approach and directly contrary to the person-centered approach we pretty much all claim is holiest and most efficient. (Note: This last point is the commonest hypocrisy in our system and your correspondent is usually guilty of it before swallowing the lees in his first cup of coffee.)
(Anecdote warning) My biggest regret from all my time in this field is this: Once upon a time, when I had done this work for about a year, a man who gave his name as Michael called and said he wanted to hire ¡Arriba! using his own money because he was living in a group home and the "independent living training" he got from the home wasn't helping him to move out (!) on his own. He said he had asked for ILS training from Lanterman Regional Center and been told that ILS services were not available to people who live in group homes because the group homes were supposed to provide that help. The thought of letting a client pay privately for services the regional center center should have provided was appalling but I have regretted ever since not asking his full name or offering help to get ILS into his IPP. This anecdote serves two purposes in this post: The first is as a caution that sometimes it can be a very good idea to have more than one agency provide services to the same individual, such as when there's a conflict in interest like expecting a residential facility to help an individual move out. Second, that while I sadly do not know the details of this case and there may have been logic to the regional center decision, it is not hard to imagine a case where a situation far better for an individual and far less costly to the State was foiled by a policy defined in terms of vendor code. Can anyone imagine a case where needless expenditures are reduced or client value added through categorizing services?
Advantages/Disadvantages: Advantages of this option include (1) Cost-savings through reduction of unnecessary administration, (2) improving the flexibility of service providers including regional centers and their vendors to be of use to clients, (3) simplifying the regulations, (4) a key step toward value-based rather than cost-based budgeting, (5) a person-centered approach to service design, coordination and implementation and (6) reduction in greenhouse gas emissions. Disadvantages include (1) costs related to retraining senior management at several regional centers to do something productive or replacing same, (2) creepy feeling that once-reliable service boundaries are giving way to free love and poetry slams, (3) priestly positions lost, some unionized and (4) loss of scale economies related to optimum use of the boards' rubber-stamps.
Total Savings: Indeterminate.
Hey, look, the DDS folks get paid to do this. You have to admit, though, green for advantages and red for disadvantages was inspired.
**UPDATE: A good friend who is also scary smart just emailed that CMS requires service codes for the waiver, which is either a deal-breaker or a proposal-changer, depending on A) what level of definition CMS regulations require of the service code and B) how the service codes are required to be applied. California defines programs by service code, but if CMS does not require that it may be possible to code for instance, activities or needs rather than programs after the fact. This was how hospital billing was often done back when I knew about hospital billing. Also, depending on CMS' definition of service code, it may be possible at least to broaden the definition to achieve some of the goals in this proposal. For example if there were one service code for housing and supervision, one for medical supplies, one for each regulated professional service and one for all others including SLS, day programs, ILS, supported employment, respite, social/recreational, waste, fraud and abuse.