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Trying to make sense of DDS’s budget numbers

November 14, 2011 5 comments

It’s hard to figure out what to make of the administration’s spending decisions when it comes to providing services to people with intellectual disabilities in Massachusetts.

On the one hand, since Fiscal Year 2009, the administration and Legislature have cut most community-based line items, including adult family supports (26.9% cut), community transportation (17.6%), community day and work (3.8%), Turning 22 (35%).

Not suprisingly, the developmental centers line item in the budget has been cut since FY 09 by $45.4 million, or 24.2%.  (In fact, based on a set of numbers provided by the Department of Developmental Services, the budgets of the Templeton, Monson, and Glavin developmental centers alone were cut by almost 70 percent between FY 09 and FY 11.)

Yet, at the same time, the community residential line item (which funds contract-based care in privately operated group homes) has been raised since FY 09 by $182.2 million, or 32%.  In addition, the state-operated group home line item has been boosted by $27.4 million, or 19.9 percent, in that time.

 These two community residential and state-operated group home line items have been boosted by a total of $209.6 million, while the cuts have totaled $87.4 million during the same period (not counting the planned phase-out of funding under the Boulet lawsuit).   The bottom line is the grand total of all DDS line items is $34.6 million higher in the current fiscal year than it was in FY 09.

What exactly has been going on here?  We’ve asked DDS for information on where residents of the developmental centers targeted for closure have been transferred.  We don’t believe very many residents have opted to live in privately operated group homes.  So it remains a mystery to us just why the administration has needed to boost the community-residential line item by more than $180 million.

It’s true there are potentially thousands of people waiting for community-based residential care.  But if indeed more than $180 million in new state dollars have been put toward accomodating people waiting for residential services, why has the administration been cutting funds for transportation, day programs, family support, Turning 22 and other programs for those same people?  

It would seem that had the administration pared back the increase in the community residential line item to a modest $100 million increase since FY 2009, they could have prevented the cuts in the other community line items at at least held them harmless.  It’s strange because the administration’s funding decisions have left it open to the charge from the Association of Developmental Disabilities Providers that the administration has failed to back its “professed interest in Community First,”  an initiative intended to boost community-based services choices and spending. 

In the meantime, DDS has denied a request by COFAR for records detailing community-based costs of a particular community-based residential program.  We’ve been seeking to compare costs and services under this particular contract with the budgets of the Templeton, Monson, and Glavin Centers from FY 2009 to the present. (We don’t believe that the cuts in the developmental center budgets will save money in the long run because these same services must be funded in community-based accounts if they aren’t funded under the developmental center budgets.)

We asked for both a breakdown of the Templeton, Monson, and Glavin budgets and records detailing the costs of medical, nursing, clinical, and therapeutic services provided to residents of the group home program.  In a letter dated October 23, DDS’s general counsel stated that the documents we requested concerning the group home program are part of DDS clients’ records and are therefore exempt from disclosure.

COFAR has appealed the denial to the state Division of Public Records, arguing that we are not seeking information that identifies any specific individuals.  What we want to find out is which agency or agencies both fund and provide the medical, nursing, clinical, and therapeutic services under this contract, and how much these services cost state taxpayers in total. 

We believe DDS can provide the information we are seeking without violating the privacy rights of the individuals in this program.  Should DDS refuse to provide this information, the public will have no way of knowing basic details about the provision and cost of these kinds of public services.

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Another forgotten cost of closing developmental centers

October 14, 2011 1 comment

One of the costs of closing developmental centers for the intellectually disabled, which rarely gets considered in budgetary “savings” analyses, is the cost to affected communities in lost economic activity, jobs, and tax revenues.

Two studies done in Kansas and Illinois have each projected economic impacts of tens of millions of dollars annually on local communities in closing a developmental center in each state.  We have yet to locate such a study in Massachusetts, even though the Patrick administration has targeted the Fernald Developmental Center in Waltham, the Glavin Regional Center in Shrewsbury, the Templeton Developmental Center, and the Monson Developmental Center in Palmer for closure by the end of the coming fiscal year.

Developmental centers provide both direct economic benefits to their surounding communities from employee salaries and so-called ripple or multiplier effects.  Ripple effects include “indirect” sales and jobs in area businesses such as food distributors and office supply firms that provide goods and services to the developmental centers.  And those ripple effects include “induced” sales and jobs supported by the developmental center employees when they patronize restaurants, gas stations, banks, grocery stores, computer stores, convenience stores and much more.

An August 2011 report to the Illinois Department of Human Services by the Institute of Government and Public Affairs at the University of Illinois concluded that closing the Jacksonville Developmental Center in Jacksonville, Ill., would affect 591 jobs and have a ripple effect on $47 million of economic activity in Morgan County and $17 million in the city of Jacksonville. 

In addition, according to the University of Illinois report, the closure of the Jacksonville Center would result in $590,000 in lost state sales and income taxes paid by employees who were laid off and by suppliers to the facilities.

A September 2009 report prepared for the Greater Topeka Chamber of Commerce  on the impact of the Kansas Neurological Institute on the economy of the Topeka area during Fiscal Year 2010 found a direct economic impact of $28 million from the developmental center and an additional ripple effect of $37 million.  Taking into account the KNI’s 570 workers, the developmental center supports a total of 1,311 jobs in the local community, the report said.

The KNI report, written by Impact DataSource, a Texas-based economic consulting and research firm, added that the Kansas developmental center generates some $447,000 a year in local sales taxes and $3.3 million in local property taxes.

In testimony last February to a Kansas legislative committee,  Christy Caldwell, a spokeswoman for the Topeka Chamber of Commerce stated:

If the motive for closing KNI is saving the state dollars, we respectfully ask your very careful consideration of whether there will be real cost savings.  We ask that you consider the economic impact on Topeka; a significant loss for this community, should there be closure.

In Massachusetts, a Department of Developmental Services working group recommended in 2002 that prior to closing any developmental centers, DDS undertake an analysis of the multiplier effect of the closures on the local economies.  The working group also recommended consideration of other factors, such as the community use of the facility and the grounds, cost implications of the use of facility space by other government agencies, projected mothballing costs, and projected “ramp-up” costs for new community programs. 

We’ve checked with state legislators in whose districts the Fernald, Templeton, Glavin, and Monson developmental centers are located, and with local chambers of commerce, and haven’t yet found any such economic impact studies done of  the potential closures of the facilities.  We’ve filed a Public Records request with DDS, asking for any such analyses that may have been done.

The University of Illinois study noted that in additional to quantifiable economic impacts of the Jacksonville center’s closure, there are many less quantitative impacts such as the effect on charitable contributions – both time and money – by the facility employees and the impact of the re-location of facility employees and their families on school district enrollments.  “All of these more qualitative impacts contribute to the fabric of the local community and may be valued just as highly – even if they are more difficult to measure,” the report stated.

There is, of course, the question whether the loss of economic benefits from the closures of the developmental centers might be outweighed by the potential for reuse of the properties.  But those benefits in reusing the properties are largely speculative compared with the concrete benefits provided by the developmental centers themselves.  Caldwell stated in her testimony that the previous closure of the Topeka State Hospital “did not garner the private interest and investment (in the former hospital land) that many believed could be gained when the facility closed.”

In addition to undertaking economic impact analyses prior to closing the four developmental centers in Massachusetts, policy makers in this state should reassess the value of the properties involved and what they could reasonably expect to receive for those properties, given the current state of the economy.

Gov. Patrick should look at contractors’ salaries too

February 28, 2011 7 comments

The Boston Globe ran a front-page story yesterday announcing that Governor Patrick is reviewing the salaries of chief executives and lower-level workers at the state’s 42 independent agencies and will reduce those he believes are excessive.   Many of these executives earn more than twice Patrick’s own salary of $140,000.

The governor is also seeking to combine agencies or eliminate jobs to further cut costs in the next year.  These independent or quasi-public agencies run the gamut from Massport, which runs Logan Airport, to the Massachusetts Technology Developmental Corporation, which provides venture capital funding to startup companies.

This is all well and good, but we would urge the governor to take a look as well at salaries in the state-funded human services vendor industry in Massachusetts.   There are hundreds of these companies that contract with agencies in the Executive Office of Health and Human Services, and the salaries of the executives running them are often above $100,000 as well.   In 2009, we looked at a few of the firms that contract with the Department of Developmental Services.   A few examples from among the vendors that we reviewed that year were the following:

  • Vinfen:  8 executives making over $100,000 a year, with the president making $376,000, including benefits.
  • Justice Resource Institute: 7 executives making over $100,000.
  • Seven Hills: 4 executives making over $100,000, with the president and CEO making $520,600, including benefits.
  • Work, Inc.:  5 executives making over $100,000.

These salaries are a problem because there are so many of these companies contracting with the state.  As services once provided by state employees have been privatized over the past 30 years, the number of people drawing high salaries in the contractor industry has grown exponentially.  Those salaries are part of the cost of care in the community-based system, which the taxpayers fund. 

While the administration has tried to portray the DDS developmental centers, for instance, as unduly expensive, there used to be only one set of administrators in each center drawing relatively high salaries (although few, if any, of them made salaries above $100,000).  

The executives of the contracting firms that have replaced the developmental centers and other state-run operations constitute a new and even more expensive layer of bureaucracy that is soaking up state funds.  This is one reason why we believe privatization in general doesn’t result in predicted savings.  

There is also an increased potential for fraud and waste in our highly dispersed, contracting system because the state doesn’t have the capacity to oversee it nearly as well as it was able to oversee functions once provided by state employees.  This has left the contracting system vulnerable to fraud, waste, and poor care provided by inadequately trained direct-care workers, whose salaries, by contrast, are low.

In Wisconsin, we are witnessing a battle over the value of public service as state employees there rise up to defend their collective bargaining rights.  Let’s not forget, though, that privatization over the long run is just as effective as the direct elimination of collective bargaining agreements in weakening public employee unions and workers’ rights.  Both strategies ultimately throw people out of work and produce a largely low-paid, non-union workforce.

And both strategies tend to result in an expansion of contracted services as the public sector loses more and more of its capacity to manage its affairs due to continual downsizing of its workforce.

The difference between these two strategies is that privatization is not seen as being as overtly confrontational as eliminating collective bargaining.  So our own governor can engage in major privatization initiatives that weaken public unions while still claiming to be a friend to them.  

That’s why we hope that in addition to scrutinzing the salaries of the executives of the independent agencies, the Patrick administration will at least take a look at the state’s human services contracting system.  We think there is as much, if not more, fertile ground for savings there.

Update: We just received some cost records from DDS…but

February 21, 2011 1 comment

On Friday, I received a letter and some short spreadsheets from the Department of Developmental Services in response to our Public Records request for documents supporting the administration’s cost analysis in closing three developmental centers in Massachusetts

The administration’s cost analysis, which was submitted to the Legislature last summer, concluded that closing the Templeton, Monson, and Glavin developmental centers would save tens of millions of dollars in state funds. As readers of our posts know, we’ve long questioned that claim.

It took two and a half months to get a total of six pages from DDS on Friday, and it only happened after we filed an appeal for the documents with the State Supervisor of Records.  The problem now is that these six pages do not appear to be responsive even to our pared-down documents request in January.  We will probably have to file another Public Records request with DDS and we may continue our appeal with the state Public Records Division.

Still, the documents we’ve received so far do shed a little light on how the administration came up with its projected savings in closing the Templeton, Monson and Glavin Centers and transferring a projected 274 of their residents to community-based residences and to the Wrentham Developmental Center. As we suspected would be the case, the documents indicate that many important costs of community-based care were left out of the administration’s analysis. And, as we’ll explain below, at least part of the analysis is based on an inappropriate apples-to-oranges comparison of developmental center and community-based residents.

First, I’d note that the administration appears to have submitted two entirely separate analyses in the same report to the Legislature on the cost of closing the centers.  The first analysis primarily used DDS budget costs and came up with a $14.7 million annual savings in closing the centers; and the second analysis used what were described as “fully loaded costs,” meaning they included some additional fringe benefit and other costs that DDS factored in. That analysis came up with a $20.3 million annual savings in closing the centers.

The records I received on Friday indicate that the administration’s first analysis was based largely on what the records stated is a $150,000-per-person, yearly cost of operating a group home for eight former residents of the Fernald Developmental Center.  (This appears to be a group home in Bedford, although the DDS letter I received on Friday doesn’t identify it as such.)  The analysis multiplied the $150,000 cost of the group home by 97 Monson, Templeton, and Glavin residents projected to be transferred to new community-based residences, and came up with a total cost of care in new community-based residences of $14.5 million.

(We had specifically asked DDS for documents supporting that $150,000 cost. The only thing DDS provided us was a one-page budget sheet, which the DDS letter stated was a budget for the group home for Fiscal Years 2008 through 2011. It’s unclear from this budget sheet, though, how the $150,000 cost was calculated.)

As part of the same analysis, the administration also determined that it would cost $95,000 per resident to place a projected 76 former Monson and Templeton residents in existing community-based homes (total $7.2 million), and $135,000 per person to place 42 Glavin residents in existing community-based homes ($5.7 million). The administration also determined that it would cost $70,000 per resident to place a projected 59 residents at the Wrentham Center ($4.1 million). The total cost of closing the three developmental centers was therefore determined to be $31.6 million.

(Despite our request, the DDS provided no backup documents showing how those figures for placing Monson, Templeton, and Glavin residents in existing homes or in the Wrentham center were derived. Why was the Wrentham center cost only $70,000 per resident, for instance, if developmental centers are supposed to be so expensive?)

The analysis then used the Fiscal Year 2009 bugets of the Templeton, Monson, and Glavin centers to determine costs per person in each, and multiplied those figures by the number of residents projected to be transferred from each facility to determine a cost of keeping the three centers open ($46.3 million).

The analysis concluded that closing the developmental centers will therefore result in an annual savings of $14.7 million. 

Unlike the first analysis, the second analysis appeared to be based on the average cost of care in the community-based system as a whole. The administratation appears to have first calculated a fully loaded community residential cost in Massachusetts in FY 2009, which was listed as $603.2 million for vendor-operated homes and $163.8 million for state-operated homes.  It’s not clear where those numbers came from, but they appear to track line items in the FY 2009 state budget for community residential and state-operated group homes.  The numbers are a little higher than the budgetary line items possibly because they are fully loaded figures.

This cost analysis then added $19.2 million for day services and $16 million for transportation services to the other two amounts for vendor and state-operated residential care to derive a total community-based cost of care that could be compared with the cost of operating the Templeton, Glavin, and Monson centers.  (Again, it’s unclear where the day services figure came from, in particular, because the Day Program line item in the budget in FY 2009 was around $128 million.)

The DDS documents show that the administration then calculated yearly, per-person costs for residential care, day services, and transportation in the community system, which were then added together.  That sum was multiplied by the 215 residents projected by DDS to be transferred from Templeton, Monson, and Glavin to both new and existing homes in the community system. The total annual cost of community-based care for those residents was projected to be $30.3 million.

Next, the administration calculated a fully loaded cost of transferring a projected 59 residents from Templeton, Glavin, and Monson to the Wrentham Center, and came up with a figure for that of $13.9 million.  So the grand total of placing 274 Templeton, Glavin, and Monson residents in both the community system and Wrentham came to $44.3 million per year.

Finally, the administration used the Glavin, Templeton, and Monson budgets for FY 2009 to calculate a total, fully loaded cost of serving the same 274 residents, and came up with a figure of $64.6 million.  The administration concluded that there would therefore be a savings of $20.3 million in closing the developmental centers.

Here are some of the questions we have about both analyses:

First analysis:  The budget sheet for the group home for former Fernald residents lists certain staffing and other costs for the group home in Fiscal Years 2008 through 2011, but it doesn’t break those staffing costs down in any way.  As a result, it’s impossible to judge whether the costs listed for the group home are comparable to the developmental center costs cited by the administration.

For instance, does the $818,224 listed as employee compensation in the group home budget in FY 2009 include staffing for day programs outside the home?  Does it include the cost of transportation and medical care for the residents?  Does it include day habilitation costs, and service coordination costs?  We don’t think it does; yet, all of those costs are included in one way or another the budgets of the developmental centers.

It was also unclear how the numbers on the budget sheet relate to the claimed $150,000 cost of operating the group home. And does that $150,000 include housing subsidies and food stamp costs, which help pay for housing and meals in the community system?  Again, we don’t think those costs are included.

Also, we would question the validity of basing an analysis of the cost of care in new community-based homes on the cost of care of just one group home. Among other questions, are the particular Fernald residents in the Bedford home representative of all residents in the facilities slated for closure?

Second analysis:  How were the figures for community residential, state-operated residential, day, and transportation costs derived in the fully loaded cost methodology?

Do the Bedford group home costs factor in any way into this fully loaded cost analysis?

Also, is the methodology of this analysis based– as it appears to be– on a comparison of the average cost of care in the community with the average cost in the three developmental centers?  If so, this is the apples-to-oranges comparison we’ve been talking about all along. The developmental centers serve older, more medically involved, and more intellectually disabled persons than does the community system on average. As a result, transferring those people from the developmental centers to the community will not necessarily result in a savings.

As is the case with the first analysis, do the community-based costs in the fully loaded cost analysis include medical care, day habilitation, service coordination, housing subsidy, and food stamp costs? We don’t think those costs are accounted for here either.

In both analyses, is the relatively small number of people projected to be transferred to Wrentham realistic? Using the administration’s figures, if more people were transferred to Wrentham, the projected savings in closing the Templeton, Monson, and Glavin centers would drop.  

Finally, do either of these analyses include the cost of further renovations at Wrentham that would have to be done to accomodate the additional residents projected to be sent there? We don’t think they do.

The bottom line is that in our view, numerous questions surround the administration’s claimed savings in closing the Templeton, Monson, Glavin AND Fernald developmental centers (Fernald wasn’t even included in the cost analyses submitted to the Legislature). We therefore have a couple of questions for the members and staff of the House and Senate Ways and Means Committees and the Children, Families, and Disabled Persons Committee, which received the administration’s cost analyses last summer:

Has anyone on these committees actually reviewed these analyses, and, if so, do they have any of the same questions we do? Last fall, we wrote to the three committees, raising some preliminary concerns about the cost analyses. We’ve still not heard back from them.

We’re still waiting for the administration’s cost documents

February 15, 2011 3 comments

Almost two and a half months ago, we asked for public documents from the administration to support its claim that the state will save money in closing four developmental centers in Massachusetts for persons with intellectual disabilities.

We’re still waiting.

Our December 3 request was for specific documents backing up a cost analysis submitted by the administration to the state Legislature last summer.  The cost analysis claims that the closures of the four developmental centers — Fernald, Templeton, Glavin, and Monson — will save the state $40 million a year.

Lest you think our request was overly broad, we offered last month to narrow it to a request for documents primarily supporting a specific projection in the administration’s analysis that it would cost $150,000 per person to place residents in new community-based homes.  That figure compares with $172,900 per resident that the analysis contends is the average cost of operating three of the developmental centers targeted for closure.  The difference of $22,900 is part of the savings claimed by the administration in closing the centers.

So far, we’ve received no documents.  In fact, the last I heard from the administration on this matter was a December 21 letter from the general counsel of the Department of Developmental Services, stating that the agency would have to search for the records we were requesting and that the cost of the search was likely to exceed $100.  The letter stated that the general counsel would contact me as soon as she determined the precise cost of searching for and copying the documents.

It’s interesting that DDS would  have to search at all for documents used to back up a major cost analysis that was submitted to the Legislature only last summer.  One would think DDS officials would know where these records are.

One would also think that by now, the general counsel would have at least determined the actual cost of such a search.  After all, the state’s Public Records Law [M.G.L. Chap. 66, Section 10 (b)] states that custodians of public records must comply with public records requests within 10 days.  The regulations accompanying the law [950 CMR 32.05(2)] further state that requested public records should be provided “without unreasonable delay.”  Nearly two and a half months since we first submitted our Public Records request, we haven’t even been told what the cost of searching for those records might be.

On Feb. 4, not believing that DDS was in compliance with either the letter or spirit of the Public Records law or regulations, I contacted the state Supervisor of Records, who can ultimately refer these matters to the atorney general or a district attorney.  As of Feb. 11, a staff person in the Supervisor’s office told me that DDS had not responded to a fax she had sent to them, asking about our records request, and that she was going to send them a letter. 

We asked for these documents for a number of reasons.

First of all, we believe the administration’s methodology in comparing developmental and community-based costs is flawed.  The cost analysis appears to be based on a comparison of the average cost per resident of community-based care and the average cost of care in the Tempton, Monson, and Glavin centers.  The problem is that the residents of the developmental centers are older and  have higher levels of intellectual disability and greater medical needs than the average community-based resident.  The average age of residents in those three facilities is 57.5, according to the cost analysis itself.  In other words, the administration appears to be making an apples-to-oranges comparison.

Secondly, we believe that the $150,000 community-based cost figure projected in the administration’s analysis may not include at least some charges that have been shifted to the state’s Medicaid budget.  Day Habilitation services, for instance, which are a key element of the care of persons who have been transferred from the developmental centers to the community system, are paid from Medicaid.  Similar services, which are provided in the developmental centers, come from the DDS budget.  The administration appears to be comparing costs only within the DDS budget of developmental centers and community-based care.

We don’t feel as though we’re grasping at straws here in trying to demonstrate that the cost of community-based care is not necessarily less expensive than developmental-center care for comparable residents.  As we’ve previously reported, the State of Connecticut has projected that closing that state’s remaining developmental center would result in higher costs, not savings.

After we sent out a press release late last year expressing our concern about the apples-to-oranges comparison of costs, a spokesperson for the administration claimed to The Springfield Republican that the administration’s projections “have been accurate so far.”   If that’s the case, then the administration should be eager to provide the documents we’ve requested, which would show what those projections are based on.  The administration, however, seems to have shown a notable lack of eagerness to provide those documents.

Where, again, are those savings in closing the developmental centers?

February 11, 2011 Leave a comment

The Patrick administration has repeatedly assured the public that it intends to plow tens of millions of dollars in projected savings in closing four state developmental centers back into the community system of care.
 
But now, even the staunchest advocates of the developmental-center closures appear to be starting to question whether the community system is deriving any fiscal benefits from the planned shutdowns of the Fernald, Monson, Glavin, and Templeton centers.
 
In the current and coming fiscal years, Day Habilitation services, a key community-based budgetary line item is getting hammered by the administration.  And the Association of Developmental Disabilities Providers and the Arc of Massachusetts, which have pushed hard for closures of the developmental centers, are up in arms about the cuts.  Day habilitation involves a coordinated system of speech language therapy, occupational therapy, physical therapy, behavioral management, developmental skills training, and other programs for persons with intellectual disabilities.
 
In a series of press releases and emails to their members over the past week, the ADDP and Mass Arc have decried cuts of $1.6 million in the current fiscal year and $5 million in the coming year in Day Habilitation services.  
 
That may not sound like a lot of money being cut, but in an email to members, dated Feb. 4, the ADDP describes Day Habilitation services as a key component of the administration’s “Community First” initiative, which is centered around the closures of the developmental centers.  Day Habilitation should be one of the prime beneficiaries of the money supposedly being saved in closing the centers.  But it’s not deriving any benefit at all.
 
As the ADDP email states:

Over the last several years, the Commonwealth has turned to Day Habilitation programs to provide the day activity for state owned and operated group homes, as well as hundreds upon hundreds of people with disabilities who have moved from state institutions into community settings.

In fact, the Administration’s Community First, Institutional Closure and Olmstead Plans make heavy use of Day Habilitation services by moving former residents of Fernald and other closing state institutions into state owned and operated group homes and private provider day habilitation programs for non-residential supports and services (the state doesn’t operate similar day activity programs).

The proposed Mass Health Day Hab cuts means that there will be less staff on hand to serve many frail individuals who have a variety of challenging health concerns, as well as cognitive impairments.  
 

In 2008, Health and Human Services Secretary JudyAnn Bigby claimed to The Boston Globe that the administration would be plowing $45 million a year back into the community system as a result of the shutdowns of the developmental centers.  As of today, it doesn’t appear, however, that the administration is even able to prevent further cuts in one of the key components of its community-based approach.
 
It’s worth noting here is that Day Habilitation services are funded out of the state’s massive Mass Health budget, and not from the budget of the Department of Developmental Services.  Yet, similar habilitation programs in the developmental centers are funded under the developmental center line item in the DDS budget.  So, once again, while the administration may be claiming that closing the developmental centers will save money, what it is really doing is shifting DDS costs to other budgets and not adequately  funding those budgets. 

Bottom line: Rather than saving money, the administration has compounded its problems by both closing developmental centers and cutting the Day Habilitation line item.  The line item cut is a huge and scary loss and a problem for those who currently use Day Hab programs and those for whom it is proposed as they leave the developmental centers.  It is not solved by closing the centers, and in fact adds even more people into this overburdened system.

We need an independent cost analysis in closing developmental centers

February 11, 2011 1 comment

It has become apparent to us that the state Legislature needs to commission an independent analysis of the costs and benefits of closing developmental centers for persons with intellectual disabilities in Massachusetts.

We have just reviewed a purported cost-benefit analysis that was submitted to the Legislature last July by the Executive Office of Administration and Finance regarding the planned closures of the Monson, Templeton, and Glavin Centers. 

For one overriding reason, which I will explain below, we consider this analysis to be meaningless. Yet, the Legislature is relying on it in making the decision to approve the closures of these critically important state facilities. (The Legislature has already given its okay to the closure of the Fernald Center without even requiring the administration to submit any cost numbers whatsoever.)

First, a bit of background about the EOAF cost analysis. The submission of the report to the House and Senate Ways and Means Committees and the Joint Committee on Children, Families, and Persons with Disabilities was required by language in the Fiscal Year 2010 state budget. While the Legislature was considering that budget, the administration was lobbying heavily against including Fernald in the cost analysis, and ultimately got its way. But it’s a puzzle as to why Department of Developmental Services Commissioner Elin Howe, in particular, fought so hard to exclude Fernald, because the cost analysis produced by the administration for closing the three other facilities is so self-serving.

 Here’s the key flaw in the analysis: The EOAF analysis compares what it terms “fully loaded” costs of operating the Monson, Templeton, and Glavin Centers with community-based costs (plus alternative facility costs reflecting “anticipated placement decisions.”) “Fully loaded” simply means the costs include health benefits and other indirect personnel costs paid for by agencies other than the DDS. 

The EOAF report concludes that the community-based and alternative facility costs are lower, and, thus, closing the Monson, Templeton, and Glavin Centers will save $20.3 million a year, based on FY09 rates. But the comparison is meaningless because the populations being compared are different.

The Monson, Templeton, and Glavin costs were calculated by dividing their total FY09 budgets by the number of residents in each facility. The community-based costs were calculated by dividing community-based line items in the FY09 budget by the number of residents in the community system.

The problem is that the Monson, Templeton, and Glavin residents are, on average, older, more intellectually disabled, and more medically involved than are residents on average in the community system. (One of the charts in the EOAF report lists the average age as 62.3 at Monson, 59.2 at Templeton, and 51.1 at Glavin.)

For that reason, the developmental center residents require more care on average than do community-based residents, which means that more staffing is needed per developmental center resident, which means the cost is higher. But that does not mean that there will be a savings if the Monson, Templeton, and Glavin Centers are closed. The reason is that when those residents are transferred from the developmental centers to community-based residences, their higher staffing needs will remain. If, as the administration promises, former developmental center residents will receive equal or better care in the community system, the staffing needed to serve them will need to be higher than what is needed for the average community-based resident.

 For that reason, we contend that a more valid approach to the analysis required by the Legislature would involve taking a statistically valid sample of residents in the community system who have the same average age and level of intellectual disability and medical issues as the residents at the Monson, Glavin, and Templeton Centers, and only then comparing the services, staffing levels, and cost of care in the two settings.

In fact, an analysis of 250 cost studies in the journal Mental Retardation concluded that when equivalent populations were compared, cost savings were relatively minor when institutional settings were closed; and, if there were any savings at all, they were likely due to staffing costs when comparing state and private caregivers. (Kevin K. Walsh, Theodore A. Kastner, and Regina Gentlesk Green, Mental Retardation, Volume 41, Number 2: 103-122, April 2003.)

There are numerous other flaws and misstatements in the EOAF analysis. Here are just a few:

  • The EOAF report lists projected capital expenditures that it contends would be necessary if the Monson, Templeton, and Glavin Centers were to remain open. However, the report fails to list corresponding capital expenditures that will be needed to develop new community-based residences for the Monson, Templeton, and Glavin residents. The EOAF report projects that a total of 213 residents of those facilities will be transferred to new and existing community and state-operated group homes.
  • The EOAF report states that there is “virtually no new demand for facility beds” due to expanded community-based options for individuals created through legislation. This claim ignores the vast majority of the residents of the Fernald Center who have chosen facility beds rather than to be transferred to community-based housing, and it ignores the 59 residents of the Monson, Templeton, and Glavin Centers, who are projected in the EOAF report itself to chose beds in other developmental centers. The report also fails to mention that the developmental centers have been essentially closed to new admissions since the 1980s and that people waiting for DDS supports and services have been largely prevented from choosing the centers as residential options.
  • The EOAF report implies that community-based options are sufficient for everyone who wants or needs them. The administration has never explained how it can promise comparable or equal or better services in a community system in which strict Medicaid requirements that apply to the developmental centers have been waived, and which is admittedly under-funded. The report also neglects to mention that the people waiting for community services in Massachusetts may number in the thousands.
  • The EOAF report claims that the DDS’s Quality Management and Improvement System (QMIS) has been “effective in creating safe and healthy environments” in the community system. What the report doesn’t say about the QMIS licensure system is that it fails to cover the entire group home system in a comprehensive or systematic way. The House Post Audit and Oversight Committee has reported that only 20 percent of community-based group homes are surveyed for licensing each year.

In short, the Legislature asked the administration for a comprehensive analysis of the costs and benefits in closing the Monson, Templeton, and Glavin Centers and for information about the quality of care in the developmental centers and the community, among other issues. What the administration provided was a public relations document, which attempts to justify the administration’s ideology that all institutional care is bad and should ultimately be supplanted by privatized care in community-based settings.

In our view, it is imperative that an independent auditing agency conduct an unbiased and comprehensive analysis of costs and benefits subject to legislative approval prior to closing any developmental center in Massachusetts.