The requirements seem to eliminate the category of Atypical Development as a reason a child might be found eligible for services, which would reduce the number of children able to access support through EI. This would negatively impact many kids, but would especially affect children referred due to concerns about social-emotional development. Many of the assessment tools available to EI providers do not look at all components of social-emotional development, and provide broad age ranges for developmental skills in this area. If providers must find a delay of 25% or more, many children who exhibit concerning behaviors, insecure attachment, and difficulties with emotional regulation would be found ineligible and not able to access needed services-while these concerns impact the child's functioning in their day to day routines, they often do not cause a delay of more than 25%. This will place an increased burden on Part B and social services systems, as children and families who do not receive supports for these concerns early on will need more intensive support down the road.

Early Intervention services in VA have an age criteria for eligibility to be between birth and 36 months (day before third birthday). As a child exits the program, referrals are often made to Part B services (school based). For the schools, eligibility criteria is based on academic progressions as well as a higher % for developmental delays (40 while Early Intervention is 25%). Often, children referred are at a higher rate of being found ineligible for school-based services after the receiving Early Intervention services which creates a gap in needed services for children between the ages of 3 to Kindergarten. I would propose that the age criteria for Early Intervention services be INCREASED to serve eligible children birth to 4 which would reduce this gap in service. If we continue with the current gap in services, it later becomes expensive to not only the local school systems, but other community agencies as additional support and services will be needed to help the child with delays, atypical development, or diagnoses. 

Every child who receives Early Intervention automatically is provided a Service Coordinator. The Service Coordinator is similar to a Case Manager and plays a vital role in establishing the child and family with community supports and resources as needed. While there has recently been an increase in reimbursement rates, it is not enough to cover the need currently exhibited through VA. Service Coordinators are highly involved, assist families with applications and connections with community agencies (medicaid, WIC, foodstamps, waiver services, clinic services, hospitals, etc). For this coordinated care, we are recommending that Early Intervention Service Coordination rates be increased to match ID/DD services that are currently associated with Community Services Board. 

Please consider adding an eligibility criteria for children who are at high risk for developmental delays but currently are not meeting other areas of criteria