October 6, 2007
George H. Madison, Director
NYS Governor’s Office of Employee Relations
2 Empire State Plaza, Suite 1201
Albany, NY 12223-1250
Re: NYS Vision Plan
Dear Mr. Madison:
As I’m sure you are aware, the Department of Civil Services has conditionally awarded the NYS Vision Plan contact to EyeMed Vision Care. While we recognize that there is a process for Davis Vision to protest this decision and, in fact, Davis Vision has submitted a protest, we wish to add our concerns to those who have already expressed opposition to the state’s decision to select EyeMed Vision Care.
After reviewing the Technical Components of each proposal, GOER solicited our recommendation. Based on our evaluation, we recommended the selection of Davis Vision. In addition to meeting or exceeding all of the RFP’s requirements, we considered the “added-value” services that Davis Vision provides to the more than 45,000 PEF members enrolled in the state-administered vision plan as well as other intangibles that make good business sense to those of us who live and work in the State of New York. Unlike EyeMed Vision Care, which is a foreign-owned company that will handle enrollee inquiries using a call center located outside New York, Davis Vision is a New York company and administers the state account using a call center and ophthalmic laboratories located in New York.
What message is the selection of EyeMed sending to the business leaders of this state? What portion of the $54 million contact will benefit the residents of this state? Davis Vision employs over 1,500 New York State residents and has been paying well over $2 million in New York State income taxes annually. Davis Vision and its employees contribute to New York’s economy. If Davis Vision loses the NYS Vision Plan contract, it is certain to add to the number of New Yorkers who are unemployed and competing for scarce jobs. Our leaders in state government should be ashamed if this doesn’t concern them.
Since 7/1/93, Davis Vision has provided exceptional vision benefits at low cost to our members. Davis Vision has also provided benefits to other state employees for a much longer period of time. The vast majority of our members choose plan-covered frames and lenses to receive a paid-in-full benefit. We are extremely concerned that our members’ out-of-pocket costs may be significantly higher with EyeMed as the plan administrator for the following reasons.
First, EyeMed proposed eliminating the fee for dispensing eyeglasses. We suspect that, in order to make up for this loss, network providers will resort to using aggressive sales tactics to get our members to buy more expensive frames and lens materials. In addition, we know that the staff working for at least two of the network retail chains (LensCrafters and Sears Optical) earns a portion of their income based on commissions. Clearly, these employees will have an incentive to “up sell” by recommending non-plan covered items.
Out-of-pocket costs are also likely to be higher for non-plan covered items such as enhanced frames, progressive addition lenses, Transitions ® lenses, and anti-reflective coating. Currently, our members pay a fixed surcharge for these items when purchased from a Davis Vision network provider. For example, the surcharge for progressive addition lenses is $102.32. According to Davis, this represents a savings of 32-66% off retail pricing. EyeMed proposed a minimum discount of 20% off retail for non-plan covered items. Not knowing the specific retail price or the discount that will be applied, we cannot judge whether the cost under EyeMed is more or less. However, if we assume that the retail cost is close to the same as Davis Vision and the discount applied is only 20%, our members will be paying considerably more for their progressive lenses than they are now.
Finally, we are concerned that the number of participating (par) providers EyeMed Vision Care identified in its proposal may be misleading. We based our evaluation of the EyeMed network on the assumption that all par providers are able to perform all plan-covered services and dispense all plan-covered eyeglasses or contact lenses. If this is not correct as we have now have been led to believe it poses several problems for our members. Under the existing benefit design, our members cannot “split” the benefit. They must receive all parts of the benefit, i.e., exam, eyeglasses or contact lenses, and occupational eyeglasses, at the same time from the same provider. If one of our members uses an EyeMed par provider that is an “exam only” location, s/he will only receive benefits for the exam. S/he will not be able to get eyeglasses or contact lenses from another provider because partial usage of the benefit is considered full usage. On the other hand, even if “splitting” the benefit is allowed in the new contract, many of our members will now be forced to visit two separate providers to receive their services.
PEF intends to ensure our members continue to receive the same level of benefits and quality of service Davis Vision has been providing. If we identify any diminution of the value of our members’ vision care benefits or the quality of service, we will pursue all potential remedies available to us. Management’s assurances aside, we remain concerned that changing to EyeMed will adversely affect our members and be perceived as another instance of the state sacrificing quality and value at the employees’ expense.
Sincerely,
Kenneth Brynien