My new friend, PARCA writes a blog advocating Regional Center Reform. He and I agree on a lot, and I was reading his site today, where he reminded me that I haven't ground my accountability axe recently. Shame on me.
Accountability is a massive deficit in this system. How much money is spent on needlessly restricting clients, providing useless services through feckless providers, choosing costlier options to superior ones, adding layers of bureaucratic duty or regulation unaccompanied by better outcomes? I don't know and neither does anyone else. So a lot, no doubt. Lest someone accuse me of regional-center bashing, I do hereby confess the lack of accountability is systemwide and applies to vendors, regional centers, pretty much anyone taking a penny under the DDS line item. My own belief is that the lack of accountability probably does more harm than the lack of funding to consumers.
The big picture need for accountability requires a systemic, thoughtful approach and drastic reform. But here's something we can do today:
A low-cost, drip-dry way to improve the oversight in our system would be to improve transparency. This can be accomplished with a little care for confidentiality by the magic of carbon-copying. As a matter of policy, any communication sent to a provider agency can be cc-ed to their vendoring regional center. Any communication sent to a regional center, if clients' names are redacted, can be cc-ed to the Department of Developmental Services (DDS) or the Centers for Medicare and Medicaid Services (CMS.) Any communication sent to the department can be sent to CMS as well.
It's a poor substitute for a system of outcome measurements that defers to choice, but I'll wager it would help in the interim.
"Be careful for nothing; but in every thing by prayer and supplication with thanksgiving let your requests be made known unto God." -Phillipians 4:6 (KJV)
Tuesday, February 21, 2006
Thursday, February 09, 2006
A New Blog
The Vendor Leadership Forum (VLF), a subcomittee of the Eastern Los Angeles County Regional Center Vendor Advisory Committee (VAC,) has established a weblog as part of its effort to form a learning community and to be transparent to the community.
This new blog (linked permanently at left and in this post above) will open up the progress, challenges, milestones and planning of the VLF for information and feedback. The members of the VLF will all have the opportunity to describe the journey, the scenery and the adorable natives we meet along the way. We invite all of you to read and comment there.
This new blog (linked permanently at left and in this post above) will open up the progress, challenges, milestones and planning of the VLF for information and feedback. The members of the VLF will all have the opportunity to describe the journey, the scenery and the adorable natives we meet along the way. We invite all of you to read and comment there.
Wednesday, February 08, 2006
Administration
I think our system has a funny relationship with administration. On the one hand, it's almost a tenet of faith that administrative costs deprive the clients. On the other, the State and Regional Centers sure seem to come up with a lot of ideas for vendors to do more of it. There are a few things that stand out to me about the role of administration in our system.
The first is this: Our system derives its efficiency and effectiveness from the individualism in the service planning. In theory always and in reality sometimes, services provided are so well matched with the client and his or her situation that there is no waste and yet every disability-related need is met. OK, right, but the point is, the matching of service to need and the flexibility to treat each client individually clearly requires more management that one-size-fits-all solutions. Add to that our emphasis on integration and services being located in the home and in the community and it becomes clear that the quality-assurance and communications functions of administration are more demanding and more productive than in standardized, facility-based models of care.
The second thing that stands out is this: Administration and management interfere with the process by which individuals and their staff find their own way. Quality Assurance, service planning and coordination are all interventions in the organic process of person-centered support. Administration may be necessary or beneficial but it can easily be stultifying, invasive and counter-productive. Like this entire system, cost-benefit analysis should be applied to both administration and the regulations and policies that promote administration to make sure we do the optimum amount of administration the best way possible. I should clarify that by analysis I mean analysis and nothing that begins with "I think" like this post did.
The first is this: Our system derives its efficiency and effectiveness from the individualism in the service planning. In theory always and in reality sometimes, services provided are so well matched with the client and his or her situation that there is no waste and yet every disability-related need is met. OK, right, but the point is, the matching of service to need and the flexibility to treat each client individually clearly requires more management that one-size-fits-all solutions. Add to that our emphasis on integration and services being located in the home and in the community and it becomes clear that the quality-assurance and communications functions of administration are more demanding and more productive than in standardized, facility-based models of care.
The second thing that stands out is this: Administration and management interfere with the process by which individuals and their staff find their own way. Quality Assurance, service planning and coordination are all interventions in the organic process of person-centered support. Administration may be necessary or beneficial but it can easily be stultifying, invasive and counter-productive. Like this entire system, cost-benefit analysis should be applied to both administration and the regulations and policies that promote administration to make sure we do the optimum amount of administration the best way possible. I should clarify that by analysis I mean analysis and nothing that begins with "I think" like this post did.
Tuesday, January 24, 2006
Choice and Choices, Part II
The process of filtering the client's IPP through vendor codes has two major costs. The most important is to the well-being of the client. This post will explore the less important cost, to the efficiency of the system.
To recap, the process of planning and purchasing support in California's developmental system begins with the client, those the client cares to have input and the service coordinator from the Regional Center, as well as any professional support providers in place to review the clients preferences, their disabilities and to plan for whatever support will mitigate the effects of the disabilities on the individual's aspiration. Good start if done correctly.
The next step is generally to attribute the supports to certain vendor codes based on matching needs with codes, but primarily based on Regional Center POS policies. At this point, the plan becomes centered on the vendors not the clients. The efficiency cost is this: If the POS policies are taken as gospel and they too often are, there can be a gap in resources which can only be bridged by purchasing the wrong support for too much money.
Here's an example off the top of my head but not theoretical. If a Regional Center tries to contain costs by limiting units of service available based on vendor codes, one can imagine (or name) a client whose needs exceed the provisions of the POS policy. If, as often happens, the regional center seeks to maintain those policies rather than make an exception, a client can fail to live in their own home, leading to a group home which leads to a day program which typically requires transportation. The result is, and this happens frequently in this system that when $5000 per year in support doesn't suffice to maintain a client in their own home, plan B costs closer to $40,000 per year while providing the wrong services for the client.
The response often made by people defending POS policies by vendor code is that they make exceptions when following the policy will lead to the client's living in a more restrictive setting. Heck, we're required by law. Anyone who works directly with clients knows how rarely this is the case. We go through this process. There is typically a long road into crisis and a longer one back from the brink. Clients in our program have died, ruined their credit or lost their health before the evidence that the POS policies were deficient became clear enough for the exception. The client who died now costs the State nothing. The others now cost the state roughly 6-8 times what the adequate level of support would have cost.
The result is that the system does not behave like a continuous array of supports to be tailored to the client's needs and preferences. It flows like lumpy oatmeal and people get involved in day programs they neither need nor want because the group home they didn't want to live in requires it. This is a costly problem that merits fixing for the sake of the budget if not for the sake of the clients.
To recap, the process of planning and purchasing support in California's developmental system begins with the client, those the client cares to have input and the service coordinator from the Regional Center, as well as any professional support providers in place to review the clients preferences, their disabilities and to plan for whatever support will mitigate the effects of the disabilities on the individual's aspiration. Good start if done correctly.
The next step is generally to attribute the supports to certain vendor codes based on matching needs with codes, but primarily based on Regional Center POS policies. At this point, the plan becomes centered on the vendors not the clients. The efficiency cost is this: If the POS policies are taken as gospel and they too often are, there can be a gap in resources which can only be bridged by purchasing the wrong support for too much money.
Here's an example off the top of my head but not theoretical. If a Regional Center tries to contain costs by limiting units of service available based on vendor codes, one can imagine (or name) a client whose needs exceed the provisions of the POS policy. If, as often happens, the regional center seeks to maintain those policies rather than make an exception, a client can fail to live in their own home, leading to a group home which leads to a day program which typically requires transportation. The result is, and this happens frequently in this system that when $5000 per year in support doesn't suffice to maintain a client in their own home, plan B costs closer to $40,000 per year while providing the wrong services for the client.
The response often made by people defending POS policies by vendor code is that they make exceptions when following the policy will lead to the client's living in a more restrictive setting. Heck, we're required by law. Anyone who works directly with clients knows how rarely this is the case. We go through this process. There is typically a long road into crisis and a longer one back from the brink. Clients in our program have died, ruined their credit or lost their health before the evidence that the POS policies were deficient became clear enough for the exception. The client who died now costs the State nothing. The others now cost the state roughly 6-8 times what the adequate level of support would have cost.
The result is that the system does not behave like a continuous array of supports to be tailored to the client's needs and preferences. It flows like lumpy oatmeal and people get involved in day programs they neither need nor want because the group home they didn't want to live in requires it. This is a costly problem that merits fixing for the sake of the budget if not for the sake of the clients.
Wednesday, January 18, 2006
An announcement
Square Girl has generously agreed to write for this site. It's a big upgrade. Square Girl is a provider of Applied Behavioral Analysis to children with autism and a dedicated learner from them. Her blog, Girl Squared offers both the humility and cheerfulness that I simply can't provide you. Her analysis is very humane and compassionate and I can finally look forward to reading this blog myself. As a direct care provider, Square Girl has been recently confronted with how systemic dysfunction further challenges the children and families she supports. I recommend her site for wit and wisdom about her direct care service and look forward to the same regarding her perceptions of California's developmental disability system.
Part II of Choice and Choices will be up about the time I get off my dead butt and write it.
Part II of Choice and Choices will be up about the time I get off my dead butt and write it.
Thursday, January 12, 2006
Choice and choices, Part I
One of the great interruptions in the quality of lives of people with developmental disabilities, and a barrier to the efficiency of the system is the frequent failure to provide services on a continuous spectrum. The initial concept behind the Individual Program Plans (IPPs) is to assess the needs of the client in order to provide exactly what is needed to mediate the effects of the disability and provide for a meaningful life in the community. It's been widely agreed that the IPP is the central administrative and regulatory event in the provision of services in California's Developmental Disability System.
The IPP is designed to take into account the nuances that every individual brings to their own assistance. The client is expected to be both the central object and leading subject in the development of their own plan. The IPP carries every aspiration that well-meaning people have for useful service and every hope the taxpayers have for an efficient system.
Once the IPP is complete, however, the plan typically loses most of it's meaning as Service Coordinators try to allocate the meaning from the client's plan into vendor codes. Vendor codes represent modes of providing services and allow the delivery system to be regulated according to function. Most Regional Centers, often influenced by their vendor community and to a lesser extent, their clients, typically establish Purchase of Service policies (POS) based on restrictions on who can receive services from which vendor type under what circumstances and to what extent. This system offers efficiencies for the administration of a Regional Center but is just as clearly inefficient for the support of people with disabilities.
The processing of needs into codes might not be fatal where the understanding is, as it is in law, that the POS standards are guidelines for arranging things of lesser status than the POS. Essentially, the deal statute makes with the Regional Centers is: Set up your POS policies and if you can meet the client's needs within them great and if not, you must exempt the client from the policy. That's not the deal typically made between Regional Centers and clients which can often be summarized as I understand that's what you need, let me see what I got. I'll look at the POS policies.
Vendor codes makes sense to me. To assure minimum quality standards, it is necessary to regulate agencies and the vendor codes allow that to be done appropriately for broad categories of modes of service. For example, it is generally inappropriate to have three ILS clients being served by one staffperson at a time whereas at a site based program, the minimum appropriate ratio might be higher than that.
But given that services are placed in broad categories, keeping faith with clients and their IPPs requires that these categories be understood as ranges on a continuum not as separate and distinct modes. Seeking to fulfill a client-centered IPP with vendor-centered service purchasing betrays choice by limiting choices.
The IPP is designed to take into account the nuances that every individual brings to their own assistance. The client is expected to be both the central object and leading subject in the development of their own plan. The IPP carries every aspiration that well-meaning people have for useful service and every hope the taxpayers have for an efficient system.
Once the IPP is complete, however, the plan typically loses most of it's meaning as Service Coordinators try to allocate the meaning from the client's plan into vendor codes. Vendor codes represent modes of providing services and allow the delivery system to be regulated according to function. Most Regional Centers, often influenced by their vendor community and to a lesser extent, their clients, typically establish Purchase of Service policies (POS) based on restrictions on who can receive services from which vendor type under what circumstances and to what extent. This system offers efficiencies for the administration of a Regional Center but is just as clearly inefficient for the support of people with disabilities.
The processing of needs into codes might not be fatal where the understanding is, as it is in law, that the POS standards are guidelines for arranging things of lesser status than the POS. Essentially, the deal statute makes with the Regional Centers is: Set up your POS policies and if you can meet the client's needs within them great and if not, you must exempt the client from the policy. That's not the deal typically made between Regional Centers and clients which can often be summarized as I understand that's what you need, let me see what I got. I'll look at the POS policies.
Vendor codes makes sense to me. To assure minimum quality standards, it is necessary to regulate agencies and the vendor codes allow that to be done appropriately for broad categories of modes of service. For example, it is generally inappropriate to have three ILS clients being served by one staffperson at a time whereas at a site based program, the minimum appropriate ratio might be higher than that.
But given that services are placed in broad categories, keeping faith with clients and their IPPs requires that these categories be understood as ranges on a continuum not as separate and distinct modes. Seeking to fulfill a client-centered IPP with vendor-centered service purchasing betrays choice by limiting choices.
Tuesday, January 03, 2006
My (advocacy) New Year Resolutions
Resolved, in 2006 I will:
1. Not lift one finger if the only motivation is to save the (present) system;
2. Be open-minded and constructively engaged in any system-reform proposals.
3. Continue to study, implement and support the development of more efficient and client-centered service delivery;
4. Be even crankier than last year except toward clients and ¡Arriba! employees. I want to break the record.
5. Assist CDCAN in the development of it's statewide network.
6. By the end of the year not be an officer of any board or committee, except the Pomona Valleys Foundation.
7. Kick an innocent child. Insult someone important. (By January 31)
1. Not lift one finger if the only motivation is to save the (present) system;
2. Be open-minded and constructively engaged in any system-reform proposals.
3. Continue to study, implement and support the development of more efficient and client-centered service delivery;
4. Be even crankier than last year except toward clients and ¡Arriba! employees. I want to break the record.
5. Assist CDCAN in the development of it's statewide network.
6. By the end of the year not be an officer of any board or committee, except the Pomona Valleys Foundation.
7. Kick an innocent child. Insult someone important. (By January 31)
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