MAC Testimony on NJ Part C Plan for I.D.E.A.

November 5, 2003

ABSTRACT

The Melody Arons Center for Applied Preschool Research and Education has conducted a two-year study of New Jersey's Early Intervention System. Methodology utilized the statutory language of the Individuals With Disabilities Education Act as the framework within which the results of this study were framed. SICC meetings were attended, SICC documents received and reviewed, Internet searches conducted, and OPRA requests made. A summary of the financial information is presented at this time, accompanied by recommendations.

Early intervention is an entitlement program of services for eligible infants and toddlers, 0-3. Services are to be without cost to families unless state law specifies the sliding scale arrangement. No cap of any kind can be placed on the amount of free hours to be provided. New Jersey has no such state laws codifying any sliding scale arrangement. N.J.S.A. 26:1A-36.6 sets forth the only statutory language and makes no statement concerning funding of services. As a result, all services must be without cost to the families of New Jersey's infants and toddlers.

Currently the state proposes to establish a co-pay system for early intervention services, indicating that budget constraints require new solutions. MAC's research demonstrates that New Jersey's budget for EI is conflicted. The SICC statement of the state budget for 2002 is $39 million, while the official budget provided to MAC was $26,967,000, or a discrepancy of $13,033,000. There is also inconsistency as to whether or not the state budget funds infrastructure and activities for EI. No complete or verifiable information of any kind has been provided to either the public or to researchers regarding the total actual budget for EI from all revenue streams. As a result no change can be considered until an outside audit is conducted on every aspect of the state's system of early intervention.

The data shows that New Jersey has created an unaccountable system of early intervention that is, in fact, no system. Regional Early Intervention Collaboratives were created in the 1990s as surrogates for state government. These nonprofit corporations violate the basic precepts of nonprofit corporations in that they are actually arms of state government serving exclusively at the will of the state in order to receive the federal grant funds that have sustained them. That is not to say that those working for REIC's are not doing the best they can under remarkably difficult circumstances. It is to say that REICs are not independent of state control.

A growing body of research suggests that Early Head Start can better integrate Part C services at the local level on a more cost effective basis without charge to families. As a Part C provider, Early Head Start would have no financial eligibility requirement and offer the added center-based option that the present system now lacks.