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Talking Points for New CDS Rule Impacting Independent Providers
Please add your own perspective and questions based on your own experience to the talking points below. CDS will respond in writing to any questions that you include in your message. (That’s why the talking points below include questions.)
Title: You should include the following title in your communication with CDS: “Comments on Rule Governing the Child Development Services (CDS) State Intermediate Educational Unit’s Contracting for Evaluations, Early Intervention Services, and Special Education and Related Services”
What:The new rule would establish a roster of qualified independent contractors for purposes of CDS contracting for evaluations, early intervention services and special education and related services for children with disabilities birth5. Read the rule (Chapter 176) at: http://www.maine.gov/doe/rule/changes/
- Does the rule intend to convey that CDS employed staff will fill their own caseloads first before contracting with independent providers?A strong system of independent providers is necessary to fulfilling our shared goals of providing quality service to all children in need. CDS should state unequivocally in the new rule that CDS will make referrals for all children to independent contractors first and use CDSemployed staff as a safety net for children who otherwise would not be served.
- What factors will determine whether CDS confirms or declines the independent contractor’s listing on the roster?We urge CDS to clarify that all independent contractors in good standing with the necessary certifications or licensures who meet expectations and criteria will be placed on the roster. The roster should be a tool to strengthen contracting with a broad range of independent contractors rather than a barrier.
- What will be the criteria for delisting a provider? Removal from the roster is a serious matter. Independent contractors should be provided with an opportunity to fix any alleged problems before being removed. Removal of the roster should be a matter of last resort, used only in cases of ongoing and repeated failures to meet the terms of CDS contracts or serious violations of state or federal law. ● Will rates under the new rule be standardized and increased? Currently, CDS payment rates are too low. Overly low rates discourage independent contractor participation in CDS programs and have contributed to challenges in meeting the needs of all children, particularly in rural areas.