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Frequently Asked Questions:
Assistive Technology
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Q: Is time spent contacting an assistive technology vendor or a doctor regarding assistive technology billable under IFSP Development time?
A: Time to speak to the AT vendor is not billable unless the vendor has already received an AT authorization. If a provider determines that there is a possible need for AT equipment or devices, the provider must call the Service Coordinator to make the recommendation for an AT evaluation. Time to speak to the Service Coordinator to make a recommendation is considered a consultation and is billable under IFSP development time. It is the responsibility of the child's service coordinator to speak to the AT vendor concerning the equipment or devices.
Time spent to speak to a child's physician is billable as a consult under IFSP development time. However, the documentation to support a consult with the physician must justify the actual amount of time billed to and paid by the CBO.
Q: Can a provider bill IFSP Development time to consult with an AT provider about how the AT device is to function?
A: Yes. Time spent to speak to the vendor is billable under IFSP development time once the AT vendor has received the authorization to provide the equipment/device. There may be specific information that the vendor requires from the provider who will implement the use of the AT before the equipment or device can actually be ordered or information that the provider requires from the vendor after receipt of the AT. Example - An OT might contact the vendor of the AFOs to determine how to make adjustments to make them work better.
Q: Do AT providers have to have a copy of the IFSP in their files?
A: No, they are not required to keep a copy of the IFSP.
Associate Level Providers
Q: What is acceptable documentation of supervision of associates?
A: The monitors are looking for evidence that the supervisor has completed monthly supervision of direct service sessions. This may be documented by the supervisor’s signature and the date on the associate level provider’s direct case note or supervisory log. In addition, the monitors are looking for supervisory case notes (these may be actual case notes or a log) that document contact between the supervisor and the associate in regards to implementation of the IFSP services for that child.
Q: When the supervisor goes out to do a six month or annual evaluation, can this date be used as the month’s supervisory visit?
A: No, the supervisory visit must be done during a direct service session that is being completed by the associate level provider.
Q: A provider (OT and PT) wants to hire an associate to be available for subbing-when the credentialed provider is on vacation, is sick, etc. The associate would not have a regular caseload. How does the credentialed provider document supervision?
A: If the associate sees a child/ family for less than one month, there is no need for direct supervision visits during a service session. However, there must be supervisory notes that document that the provider discussed the case with the associate prior to the provision of services.
If the associate is working with the child/family for a month or more, documented direct supervision visits must occur during a service session. In addition, there must be supervisory notes that document that the provider discussed the case with the associate prior to and during the provision of services.
Q: Are there any consequences if I am unable to supervise an associate for 3 consecutive months due to the family canceling or no showing on the date that supervision was scheduled?
Yes, there are consequences. If there is no direct service supervision for more than one month in a row, the provider will be expected to refund the amount of one session.
Q: Can a credentialed provider bill IFSP development time for discussing a child with an associate level provider (the credentialed provider is not the associate's supervisor)?
A: No, the credentialed enrolled provider can only bill IFSP Development time when talking with another credentialed enrolled provider who is identified on the child's IFSP as a member of the child's service team. The associate is not enrolled. The exception is the speech language pathologists in his/her CFY year. See the "Use of Associate Level Provider" attachment found in the "Early Intervention Service Descriptions, Billing Codes and Rates" document.
Q: What happens if a credentialed provider is not documenting that there is monthly supervision occurring for the associate level provider?
A: If there is no documentation of a monthly supervisory visit, or an attempt at a monthly visit, the credentialed provider will be required to refund one date of service for each month that there is no evidence of supervision.
Evaluation/Assessment
Q: Does the initial evaluator need to have a copy of the IFSP in their file, even if they are not going to be providing ongoing services?
A: Yes.
Q: What proof do I need in my files that I have sent my evaluation/assessment to the CFC within 14 days of the authorization being issued?
A: Copy of a fax cover sheet or a case note stating that it was mailed.
General Monitoring Procedures
Q: The monitoring tool looks at whether the previous year’s CAP has been implemented? How are monitors looking at this component?
A: If there was an area with findings in the previous review, the monitors expect there to be no findings in that area for the current review. If there are findings again, this component of the tool will be marked “no”.
Q: If the provider is unable to provide documentation for dates of service that were billed to CBO, what is the penalty?
A: A refund will be required for all dates of service for which you are unable to provide documentation.
Q: If a case note is deemed insufficient, will the provider be given the opportunity to correct it prior to a refund request?
A: No. The revision of existing documentation or creation of new documentation after the fact is considered unethical practice.
Q: With an agency that is enrolled as a provider in EI, is the individual therapist or the entire agency being monitored?
A: The agency is the payee that receives payments on behalf of its employees. Therefore, the agency is responsible for maintaining all documentation for each procedure code and date of service billed to and paid by the CBO.
Q: Are monitors reviewing evaluations or just direct service billing?
A: All services billed to and paid by CBO will be reviewed, including evaluation/assessment, IFSP development, direct service, and assistive technology.
HIPAA
Q: What is needed to be HIPAA compliant?
Every payee, whether an independent provider or an organization that employs many providers, must have written internal administrative directives regarding how they shall protect the confidentiality of personally identifiable information at collection, storage, disclosure and destruction stages. These directives should cover each area listed on the provider monitoring tool. This expectation is listed on the provider agreement under #28 and #29.
In addition to the above, providers that are covered entities are required to have a "Notice of Privacy Practices" that provides an individual with adequate notice of the uses and disclosures of PHI that may be made by the covered entity, and of the individual's rights and the covered entity's legal duties with respect to PHI. A covered entity must document compliance with the notice requirements by retaining copies of the notices issued by the covered entity and, if applicable, any written acknowledgments of receipt of the notice or documentation of good faith efforts to obtain such written acknowledgment.
Q: Do providers need a signature page for each family that has been given a Notice of Privacy Practices form?
If you are a covered entity under HIPAA laws, you must have a Notice of Privacy Practices. This is looked for under the Administrative portion of the review, so monitors will not be looking for a signature page in each file. However, providers need to be aware that if you a covered entity under HIPAA, you are required to "document compliance with the notice requirements by copies of the notices issued by the covered entity and, if applicable, any written acknowledgments of receipt of the notice or documentation of good faith efforts to obtain the acknowledgement".
IFSP
Q: Can a provider bill IFSP Development Time for attending a Pre-IEP meeting?
A: No, only attending the IEP meetings are allowed to be billed.
Q: Can a provider bill IFSP Development Time for attending a medical diagnostic evaluation?
A: No, time to attend a medical appointment with the child/family is non-billable time. NOTE: See Non-billable Activities in the Service Descriptions, Billing Codes and Rates document.
Q: Who is considered to be part of the IFSP team?
A: The IFSP team includes the credentialed EI providers that are listed on the IFSP, the service coordinator, the family, and the child's physician(s) and anyone else that participated in the development of the IFSP. Please be advised that for EI there is an "IFSP team" and a "service team". The "IFSP team" and the "service team" are made up of different entities. IFSP development time for consultation services can only be billed for time spent consulting with members of a child's "service team".
Q: Who can providers consult with and bill IFSP Development time?
A: The credentialed EI providers that are listed on the IFSP, the service coordinator and the child's physician(s). Parent liaisons and SE consultants that are listed on the IFSP are also considered "service team" members and consultations concerning a child/family can be considered billable under IFSP Development time.
Q: Can a provider bill IFSP Development time for emails discussing the case with another EI provider?
A: Yes, but providers need to be careful of HIPAA regulations in regards to identifiable information - such as names, birthdates, EI numbers, etc. Under HIPAA privacy and security requirements Personal Health Information (PHI) and personally identifiable information should not be sent via the public internet system unless that information has been encrypted in some way.
Q: What type of documentation is required for attending/billing for an IFSP meeting?
A: Monitors look for the authorization or a case note documenting attendance at the meeting. Documentation must include a begin and end time.
Interpreters
Q: Does an interpreter need a Notice of Privacy Practices?
A: No, because they are not considered a health care provider under HIPAA
Q: Does an interpreter need to have policies in place to protect the confidentiality of Protected Health Information (PHI)?
A: Yes, specifically, an interpreter must have policies that address how they protect the confidentiality of PHI at collection, storage, destruction and disclosure.
Q: What specific documentation is needed for interpreters?
A: Daily documentation of services provided - including date of service, discipline for whom you interpreted services, and time in/time out. This documentation should be signed by the interpreter. Documentation should include the type of interpretation done - verbal, written, or sign. For a written translation, the interpreter must have a copy of the document to be translated and the final document after translation.
Miscellaneous
Q: Explain how make-up sessions can be done and how they should be documented.
A: If a weekly service session cannot be rescheduled within one week, it should be consider a missed session. Likewise, if a monthly service session cannot be rescheduled during the same month (which is far less likely), it should be considered a missed session.
To document a make-up session, identify the missed date of service on your case notes and document the actual date of service that the make up session occurred as required under the definition of documentation found in the "Early Intervention Service Description, Billing Codes and Rates" document. This is your provider handbook. When submitting the claim, always submit based upon the actual date of service. Not the missed date.
Q: When should a provider do a discharge summary?
A: The provider must have a discharge summary for any child that is no longer going to be receiving ongoing services. If an evaluation is completed within 30 days of discharge, this report may be labeled Final Evaluation/Discharge Summary.
Q: Is a full signature required on case notes?
A: No, initials or first initial, last name are acceptable. It should not be a form with the provider's name pre-printed on it. Always make sure that your case notes and signature or initials are legible.
Professional Development
Q: Do providers with a temporary credential have to have the Ongoing Professional Development Documentation Form completed?
A: No.
Q: Do providers undergoing an administrative review need to submit documentation of ongoing professional development?
A: Yes.
Q: Do interpreters need to submit evidence of ongoing professional development?
A: No.
Q: What are the monitor's looking for on the Ongoing Professional Development Documentation Form?
A: What are the monitor's looking for on the Ongoing Professional Development Documentation Form?
Speech Therapist - CFY Year
Q: Can a speech provider in their CFY year and the supervisor both bill for IFSP Development Time, as long as they are not duplicating consultations/services?
A: Yes.
Q: Can a speech provider in their CFY year do make-up sessions for a fully credentialed speech provider?
A: Yes, they may do make-up sessions under the supervision of the fully credentialed speech therapist.
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