SLP Supervisors Frequently Asked Questions (including questions from the 9/13/07 OSBHF SLP Supervisors Session)

Transcription

1 (including questions from the 9/13/07 OSBHF SLP Supervisors Session) BILLING 1. QUESTION: Is it okay or does it cause problems if a school-based SLP and a privately contracted SLP bill for services for a child on the same day? If it does create problems, who should take precedence? ANSWER: No, this will not cause a problem for two providers to bill the services on the same date. However, the private provider cannot render the services in a school setting (i.e. the child should not have two SLP s providing services to him in a school setting). The second provider s claims will reject because of an 852 edit (duplicate claim for the same date of service). This provider will need to contact their Medicaid program representative to resolve the claim. 2. QUESTION: A student has individual services listed on IEP. Due to a schedule change, you need to serve the child in a small group. Can you bill as group service with the note of change listed in the clinical notes? ANSWER: Yes, the provider can deviate from the IEP; however, the provider must document the reason for the deviation and bill with the appropriate code for services rendered. The change must be specifically documented in the CSNs and the size of the group can not exceed Medicaid requirements (no more that 6, LEA Manual page 2-27). Additionally, the reverse is also acceptable. If group is listed in the child s IEP yet only one student is present for the session, individual services can be billed. 3. QUESTION: Is anything being done to reduce regulations, forms, and paperwork? Do you realize how we are being regulated to death? ANSWER: Yes, several efforts are underway to reduce paperwork burdens. However, note that documentation is required not only for Medicaid billing purposes, but is also required under Chapter 115 of the South Carolina Code of Regulations for the SLP scope of practice; and, IDEA requires other documentation as well. For Medicaid billing purposes, the electronic signature process is available to districts as an alternative to reduce paperwork. Secondly, discussions are underway

2 Page 2 of 18 with Horizons Excent to streamline and incorporate various documentation forms into the IEP writing software. 4. QUESTION: If a child received Speech for multiple areas, (language, articulation, voice, etc) what code should be used? Health office will only allow one code. ANSWER. For multiple speech areas, use the code for the area in which the majority of time was spent during the session. 5. QUESTION: If administrative claiming is eliminated, will fee for service rates be increased? ANSWER: DHHS considers a number of factors (for example source of matching funds, costs such as salaries and overhead in order to render the service, reimbursement rates of other insurance carriers, etc) when determining reimbursement rates. OSBHF will always pursue additional reimbursement for health services provided by LEAs as we know the current rates do not adequately cover LEA costs. Thus, fee for service rate increases are not contingent on whether or not administrative claiming continues to exist. Note, however, that effective April 1, 2005, DHHS discontinued reimbursement for certain consultation services because such services, they determined, were incorporated within SDAC as referral, monitoring and coordination activities. At a minimum, should reimbursement be discontinued for SDAC, OSBHF will seek reinstatement of these consultation fees. CONSENT TO RELEASE/BILL MEDICAID 6. QUESTION: What happens if an IEP meeting is held in the spring of 2007 parents were unable to attend the meeting several attempts were made to obtain parent s signature on the IEP and Medicaid consent form. The documents aren t returned to the SLP until October 2007, the next school year, signed by the parent, also dated for October Are we able to bill Medicaid for services rendered from August to October or do we begin billing after the date the parent signed the consent form? ANSWER: The LEA Medicaid manual does not specify when the consent to bill Medicaid must be obtained. However, the current Sample Consent for Treatment, Release of Information, and Medicaid Reimbursement form which has been approved by the Office of Exceptional Children and the Office of School-based Health Finance includes language that allows LEAs to bill for health-related services provided prior to the date of the

3 Page 3 of 18 consent. DHHS concurs with OSBHF that LEAs can bill for services provided prior to the signed consent as required by IDEA regulations effective October Therefore, in response to this specific question, the LEA can bill for services rendered from August to October. However, to receive Medicaid reimbursement, remember that claims must be submitted within one year of the date of service. 7. QUESTION: Clear explanation of when we have to obtain a new consent? Many students have multiple IEP meetings during the year that have nothing to do with Medicaid reimbursable services. ANSWER: A new consent is required whenever there is an IEP annual renewal, or if the IEP is amended. If the IEP meeting purpose is to change the child s math goals, a new consent/release is not needed for Medicaid billing purposes. The consent/release is consent to allow the school to release student information to SC DHHS to bill for Medicaid reimbursement. Therefore, an IEP meeting resulting in a change to the scope, frequency or duration of medical services also results in the need for a new consent to bill Medicaid. 8. QUESTION: Does any change at the IEP meeting mean that a new consent must be signed, regardless of whether the change is made by a teacher or a therapist? ANSWER: A new consent is needed only if the medical services (scope, duration, frequency) for which you will seek Medicaid reimbursement have been changed. If the change is in the child s math goals for example, a new consent is not required, for Medicaid billing purposes. 9. QUESTION: Under the new Federal law school districts will no longer be required to get parent permission for change in category and re-evaluations. How does that tie in with consent for treatment/release permission under Medicaid for IEP change(s) and re-evaluations? ANSWER: Parental consent is required for the following: initial evaluation, initial provision of special education services, re-evaluation, and release to share student information for the purpose of billing Medicaid for health-related services. Informed parental consent is not required for the following: change in or addition of category of disability and change in program model.

4 Page 4 of 18 EXCENT QUESTIONS 10. QUESTION: Ask Excent personnel if they can add space on the IEP for each objective whether it has not been mastered and the date for this entry. There is a place for it in the progress note, but not in the goal/objective section of IEP). ANSWER: It is an IDEA requirement for goals and objectives. Therefore, this is an issue that should be addressed by the Office of Exceptional Children (OEC) and not Medicaid (DHHS). The Office of School-Based Health (OSBHF) contacted Horizons Excent s Cedric Harrison who indicates that the progress report section of the IEP is designed to handle requirements related to objectives. 11. QUESTION: Can Excent modify its Medicaid billing software to incorporate the following: Electronic tracking or footprints to ensure that the integrity of documents is intact Documentation forms that enable SLPs and other providers to documents supervision and monitoring of staff requiring supervision Documentation forms that can be used for clinical service notes Documentation forms that can be used for referrals Documentation forms that can be used for evaluations ANSWER: This question has been forwarded to Horizons Excent for response related to modifications of Excent Medicaid to address SLP supervision and other documentation requirements. A meeting was held in November 2007 between OEC, Excent and OSBHF to identify/review the features of this software related to electronic records and signatures. For Medicaid billing purposes, Excent Medicaid does meet SC DHHS electronic signature requirements. 12. QUESTION: Can the Encounter Log in Excent be used in its current format to document supervision or observation of a noncertified provider? ANSWER: According to Cedric Harrison of Excent, the Encounter Log can be used in its current format for SLP supervisors to log notations of their observations of non-certified staff. 13. QUESTION: What is an Encounter Log? Is it unique only to Horizon s Excent Medicaid billing software or is it also used for some purpose with the Excent IEP writing software? What data

5 Page 5 of 18 fields of the Encounter Log are acceptable to Medicaid as evidence of observation of noncertified SLP staff? ANSWER: An Encounter Log in Excent is a tool used by providers to write their clinical service notes. There is space within each day s section of this Log to enter Medicaid required information related to observation of noncertified SLP staff. Excent offers 9 major functions, one of which is the Service Log. One of the drop down menus of the Service Log is the Encounter Log. Notation in the Encounter Log of observation of noncertified SLP staff is acceptable to OSBHF Quality Assurance Representatives when they review files for Medicaid compliance. Some districts use one of the other functions of Excent, Student/Personnel, to facilitate documentation of noncertified staff observation. One of the drop down menus of the Student/Personnel screen is the personnel information section. If a therapist is one that must be supervised, the Medicaid Administrator for the district can enter No in the field indicating Medicaid certification. With the No designation, no encounters can be extracted until the supervisor informs the Medicaid administrator when it is ok to extract the encounters. The Medicaid administrator then enters Yes for the Medicaid certified field, extracts the corresponding billings and then changes the certification field back to No until the supervisor authorizes further extractions for the therapist under supervision. The supervisor then retains notes on classroom observations and any deficiencies in the clinical service notes. OSBHF Quality Assurance Representatives will review these notes for compliance with Medicaid requirements. EQUIVALENCY 14. QUESTION: We have a master s degree SLP who has actually been granted SCLLR, but does not have her ASHA CCC s. She has met all requirements for CCC s including CFY, but her college was going through accreditation at the time. Can she bill Medicaid without supervision? ANSWER: This response is applicable only to this very specific scenario outlined above. In this instance, this person can bill Medicaid without supervision. Please note that further information was gathered related to this specific situation in order to determine that this person does not require supervision in order to bill Medicaid despite the fact that he/she does not have CCCs. A grandfathering exception was granted by LLR. 15. QUESTION: SLP with Masters had CCCs now lapsed. Can this individual continue to bill Medicaid without supervision?

6 Page 6 of 18 ANSWER: No, a person can not bill Medicaid without supervision if his credentials have lapsed. This person, however, can bill if supervised. As indicated in Section 2 of the LEA Manual, a SLP is one who meets one of the following requirements: Has a certificate of clinical competence from the American Speech and Hearing Association; Has completed the equivalent educational requirements and work experience necessary for the certificate; Has completed the academic program and is acquiring supervised work experience to qualify for the certificate. 16. QUESTION: SLP with masters never completed CFY and therefore does not have CCCs. Can this individual bill Medicaid without supervision? ANSWER: No, this person can not bill Medicaid without supervision. This person can bill if supervised. In order to bill Medicaid without supervision, this person must meet the SLP definition as outlined in the LEA Medicaid Manual (also see question # 15). 17. QUESTION: We have two therapists who have completed their masters several years ago. They both have greater than 18 years working as speech therapists. Neither therapist has their CCC's yet. They both completed supervised clinical work to qualify for their CCC's. Prior to 2005 they would have had the equivalent requirements for obtaining their CCC's minus the test scores. Now in 2007 there are additional requirements (hours and course work) needed to obtain the CCC's. Subsequently, they do not have the equivalent requirements for the CCC's any more since there are new standards. At this point are these two therapists able to bill Medicaid in the school system without supervision? ANSWER: DHHS review of Speech-Language Pathology credentials to determine the equivalency compliance in accordance with CFR includes having a current Certificate of Clinical Competence (CCC); thus, although these speech-language therapists have years of experience, they would not have the accreditation to bill Medicaid without supervision. 18. QUESTION: On Task Force for Equivalency can we consider if ever equivalent? Ex had CCC 2000, quit paying and now working. ANSWER: Per the SLP Supervisory training held on September 13, 2007, one of the recommendations is to convene a work group to address equivalency issues. Certainly, this and other possibilities can be considered by that workgroup. But, it is not probable that a person

7 Page 7 of 18 whose ASHA certificate has expired would have credentials equivalent to someone with an unexpired certificate. 19. QUESTION: Is it to my district s advantage to continue to supervise CCC equivalent SLP s until the task force has definitively recognized them as an unsupervised provider for Medicaid? ANSWER: Equivalency issues might be addressed by a not yet identified Equivalency workgroup. Districts must remain in compliance with Medicaid under the direction of policies as outlined in the LEA Medicaid Manual. Otherwise, you will not be able to bill with any certainty that you meet Medicaid provider credential requirements. EVALUATIONS AND RE-EVALUATIONS 20. QUESTION: The present levels of performance section of the IEP already include an assessment of the student s strengths, weaknesses and needs. What documentation is required to indicate yearly evaluation of a student? Is the child s assessment information that is included in the present levels of performance section of the IEP acceptable to Medicaid for meeting the yearly evaluation requirement? ANSWER: A yearly re-evaluation is not required by Medicaid. Medicaid requires a current re-evaluation. A current evaluation can be conducted twice a year or, within three years or as needed. (The child must be evaluated at least every three years). The LEA Medicaid Manual defines the re-evaluation and its purpose.... Speech Re-evaluation includes a face-to-face interaction between the Speech-Language Pathologist/ Therapist and the child for the purpose of evaluating the child s progress and determining if there is a need to continue therapy. Reevaluation may consist of a review of available medical records and diagnostic testing and/or assessment, but must include a written report with recommendations. The present levels of performance section of the IEP represents specific statements that describe the student s academic achievement and functional performance in the educational environment and must include an explanation of how the student s disability affects his/her involvement in the general curriculum and extracurricular activities. The child s assessment information that is included in the present levels of performance section of the IEP is NOT Medicaid acceptable documentation for meeting the evaluation requirement as described in the LEA Medicaid

8 Page 8 of 18 Manual in Section 2. Medicaid requires separate documentation of an evaluation of the child s progress and need for continuation of therapy. 21. QUESTION: : Is a re-evaluation for Medicaid only when formal testing is completed as needed every three years or is informal update testing before an annual review of the IEP also considered a re-evaluation? ANSWER to first part of the question - Is a re-evaluation for Medicaid only when formal testing is completed as needed every three years? No, a re-evaluation based on Medicaid and IDEA Policy is not just a formal test that is completed every three years. It could occur more frequently based on the needs of the student or at the request of the IEP team. According to the LEA Medicaid Manual, it is required that a re-evaluation is performed subsequently to the initial evaluation and related speech disorder and that a current re-evaluation be maintained in the student s Medicaid file. There is no mention of a specific three year period. Therefore, a re-evaluation can occur if necessary within a three year period or earlier. The Medicaid Policy Manual defines a re-evaluation as a face-to-face interaction between the SLP and the child for the purpose evaluating the child s progress and determining if there is a need to continue therapy. Re-evaluation may consist of a review of available medical records and diagnostic testing/or assessment, but must include a written report with recommendations. According to IDEA Policy both state and federal regulations (The Individuals with Disabilities Education Act 2004 and SBE regulation ) require that children with disabilities be reevaluated at least every three year or sooner if the parent or school requests. This requirement is found in through of the federal regulation. The results of the reevaluation are documented on a reevaluation review form. This form also includes recommendations. ANSWER to second part of the question - Is informal update testing before an annual review of the IEP also considered as a reevaluation? No, the informal testing that is done before an annual review of the IEP is not considered a re-evaluation based Medicaid s definition of a reevaluation. The Medicaid Policy Manual defines a re-evaluation as a face-to-face interaction between the SLP and the child for the purpose

9 Page 9 of 18 evaluating the child s progress and determining if there is a need to continue therapy. Re-evaluation may consist of a review of available medical records and diagnostic testing/or assessment, but must include a written report with recommendations. 22. QUESTION: Is a re-evaluation a billable service when it is indicated that the student no longer qualifies for services? (i.e. student is to be d/c. based on re-eval results). ANSWER: Yes, such a re-evaluation can be billed to Medicaid. In order to receive reimbursement for an evaluation or re-evaluation that does not result in the need for services or the continuation of services, the LEA must document the results on the IEP, on the re-evaluation plan, or on the Multi-Disciplinary Team Evaluation Report/Form. The bottom line is that there must be documentation in the child's file that the evaluation or re-evaluation was conducted and the child does not need Medicaid covered treatment services. 23. QUESTION: What do you look for in the re-eval that is required yearly? ANSWER: A yearly re-evaluation is not required by Medicaid. Medicaid requires a current re-evaluation. A current evaluation can be conducted twice a year or, within three years or as needed. The LEA Medicaid Manual defines the re-evaluation and its purpose.... Speech Re-evaluation includes a face-to-face interaction between the Speech-Language Pathologist/Therapist and the child for the purpose of evaluating the child s progress and determining if there is a need to continue therapy. Re-evaluation may consist of a review of available medical records and diagnostic testing and/or assessment, but must include a written report with recommendations. 24. QUESTION: Is this the eval plan? We need further explanation. We eval every three years. ANSWER: The re-evaluation review/plan can be the written documentation that complies with Medicaid requirements for the reevaluation. GENERAL 25. QUESTION: In Oconee, I documented that IEP (tx plans) and progress summary notes have been reviewed and accepted on the

10 Page 10 of 18 supervision (supervisory activity log) summary form for each student. This form also documents CSN, observations, etc. I have not been co-signing the actual IEP plan/progress notes. Can I continue as I have been is documenting they have been reviewed and accepted enough? ANSWER: No, please sign the IEP or a supplemental statement. Also co-sign the progress summary notes. 26. QUESTION: I request clarification in writing that child who is receiving community/private speech language therapy may receive school-based therapy both will/may bill for Medicaid reimbursement i.e. school billing will not reduce/eliminate billing/reimbursements for clinical provider. We have a private provider incorrectly telling parents not to sign consent to bill for services. We need an in writing reference to reassure parents that school billing will not negatively impact private SL service. ANSWER: Medicaid school billing will not negatively impact private Speech Language services. However, as indicated in the answer to question number 1, billing could become an issue if claims are submitted on the same date of services. IDEA/IEPs 27. QUESTION: Does the SLP who is treating the child have to be the one who signs the IEP? ANSWER: The LEA Medicaid Manual does not indicate which SLP must sign the IEP; however, best practice is for the treating provider to be present at the IEP meeting. If he or she is unable to attend the IEP meeting or if the treating provider is an uncredentialed therapist, then another SLP may submit a supplemental statement to the IEP meeting in lieu of her signature on the IEP. A copy of the supplemental statement form is included as the last page of this document. 28. QUESTION: How does the IEP differ from an ITP? ANSWER: For Medicaid purposes, an IEP is used for school-based rehabilitation services and an ITP or Individual Treatment Plan is used mostly for private services or Behavioral Health services. Page 2-29 of the Medicaid LEA Manual specifies requirements for the ITP and indicates that the IEP or IFSP may suffice as the treatment plan as long as the IEP or IFSP contains the required elements for a treatment plan as outlined on page 2-29.

11 Page 11 of QUESTION: Is the IEP signatures page not the same as continuing referral? ANSWER: For Medicaid purposes, the IEP signature page and a continuing referral are not the same thing. The IEP signature page is the documented evidence that all IEP team members were in attendance at the meeting and participated in the development of the IEP. A continuing referral means that the provider has reviewed or evaluated the IEP and current levels of performance and is recommending that the child continue to receive the same level of services as received the prior school year. Medicaid requires separate documentation of this review and recommended continuation of services. Usually, this documentation takes the form of the referral/evaluation form. MEDICAL NECESSITY 30. QUESTION: Is the medical necessity form needed for speech students? ANSWER: Medicaid requires that the service be medically necessary and that the provider s medical records substantiate the need for services. The LEA Manual on page 2-10 states Medicaid will pay for service when the service is covered under the South Carolina State Plan and is medically necessary. Medically necessary means that the service is directed toward the maintenance, improvement, or protection of health or toward the diagnosis and treatment of illness or disability. A provider s medical records on each beneficiary must substantiate the need for services, include all findings and information supporting medical necessity, and entail all treatment provided. The IEP team determines the child s need for medical services. Please note that there is not a specific rehab services medical necessity form mandated by Medicaid. 31. QUESTION: Can a certified school psychologist II sign the medical necessity as they do the LPHA? ANSWER: If you mean referral as the medical necessity, yes, a School Psychologist II or III can sign a referral as a licensed practitioner of the healing arts (LPHA) for speech and other rehabilitation services. 32. QUESTION: Is a medical necessity needed for speech, OT, PT, and OSM? ANSWER: SEE PRIOR QUESTION AND ANSWER ALSO. Medical necessity is needed for speech, OT, PT and O&M but medical necessity is not a

12 Page 12 of 18 specific document. The medical necessity for treatment is supported by the referral, the IEP, the goals and objectives, the summary of progress, the clinical service notes-- all indicate medical necessity. (In the case of referrals for behavioral services such as TBS and PRS, there is a document called a Medical Necessity Statement. But this is not the case with rehabilitative services such as Speech therapy services.) 33. QUESTION: Can a School Psychologist II sign the medical necessity required for TBS? ANSWER: Page 2-62 of the LEA Medicaid Manual lists the LPHAs that can recommend TBS. Included on this list are Licensed Psychologists. If the School Psychologist II meets the state licensure requirements of the Licensed Psychologist, then he or she can sign the Medical Necessity Statement for TBS. ON-SITE QA VISITS 34. QUESTION: If internet is down, can you conduct your visit if you couldn t audit electronic signatures? ANSWER: Yes. 35. QUESTION: If the computer systems are down when SCDE QA staff are here for an on-site visit, how would SCDE QA staff review our electronic files? ANSWER: Depending on circumstances and length of time before the computer systems are operable, SCDE staff will review whatever paper documents/files are available, or reschedule the on-site visit, or request that records be sent to SCDE by a specific date for purposes of SCDE conducting a desk audit, or other arrangements can be made related to the audit. The bottom line is that the district and SCDE do what is necessary in order for the audit to be completed. PROGRESS SUMMARY/PROGRESS REPORT 36. QUESTION: Do we still need to write a quarterly progress note as a part of our clinical notes if we have filed a progress report in the student s folder? (don t need both). ANSWER: No, you do not need to write a separate quarterly progress note for MEDICAID purposes if you have included progress assessment documentation on a quarterly basis in the Clinical Service Notes (CSNs). In such instances, the quarterly summary that is filed in the folder is

13 Page 13 of 18 sufficient. Refer to the LEA Manual in the Clinical Records section. A Clinical Service Note is a written summary of each treatment session. The purpose of these notes is to record the nature of the child s treatment by capturing the services provided and summarizing the child s participation in treatment. If these notes are then used in assessing quarterly progress and a summary assessment is indicated in the CSNs, then a separate quarterly progress form or documentation is not needed for MEDICAID purposes. If a quarterly assessment summary is not included in the clinical service notes, then quarterly progress documentation must be written and filed in order to comply with MEDICAID. One or the other is acceptable for Medicaid purposes. Both are not needed. 37. QUESTION: What is the difference between a progress report and a quarterly progress report? Are both accessible via Excent? What does Medicaid require in terms of progress reports/quarterly progress reports? ANSWER: The LEA Medicaid Manual requirement of a progress report is shown as the last bulleted item on Progress Summary Notes. No additional description is given. The form and frequency are up to the discretion of the district. The progress report is accessible via Excent. 38. QUESTION: Is a separate form required to report Quarterly summary progress? Would the progress report suffice? ANSWER: No, a separate form is not needed to report quarterly summary of progress. See above question and answer for further explanation. REFERRALS 39. QUESTION: Can a supervisor refer a student to her supervisee? So I can refer all of the students in the district to my people I supervise? ANSWER: Yes, a supervisor can refer to a supervisee. Page 2-5 of the LEA Medicaid Manual states that referral means that the physician or other LPHA has asked another qualified health provider to recommend, evaluate, or perform therapies, treatment, or other clinical activities to or on behalf of the beneficiary being referred. An SLP meets the definition of a LPHA as indicated on page 2-6 of the Medicaid LEA Manual. Therefore, a CCC SLP, SCLLR SLP or an SLP that has completed the academic program and acquiring supervised work experience (known as the clinical fellowship experience or CFY) can refer a student to another qualified health provider (in this case, the non-credentialed speech language therapist) for evaluation for speech services or treatment. The

14 Page 14 of 18 credentialed SLP (page 2-6) cannot refer the student to him/herself for evaluation for services. 40. QUESTION: Can an SLP refer to another SLP in absence of RN for evaluation? ANSWER: refer. Yes, an SLP can refer to another SLP. An SLP cannot self 41. QUESTION: If a license is not necessary to sign referrals in the public school then why does your sample referral form have LPHA credentials and License numbers included on the form? ANSWER: The referral must be obtained from a Licensed Practitioner of the Healing Arts (LPHA) acting within the scope of practice under state law (LEA Medicaid Manual pages 2-5 and 2-6). Speech Language Pathologist is included on this list. The Referral for Speech-Language Evaluation/Treatment form indicates that items in italics are not required by Medicaid BUT may of use to districts. LEAs are not required to include the LPHA license number on this form. 42. QUESTION: I have my C s but not LPHA (SC LLR) license. I work in the schools. Can I sign referrals or not? (take the license number off the form if it s not needed in the schools). ANSWER: If you are employed by the school district, and hold an ASHA CCC, you can sign referrals. Your district has discretion to require the LPHA license number on the form. Such number is not required by Medicaid but is included on the sample Referral form so that districts can collect the number should they have need or use for it. 43. QUESTION: What is the reason for a with referral and without referral? Why do we need both? ANSWER: You are referring to two forms developed by the SLP task force in January You do not need both. These forms are offered as options for districts to use. It is up to your district as to which of these forms suit your purposes. 44. QUESTION: We are one of the few professions that cannot refer to ourselves. What can be done to change this practice? ANSWER: A speech provider who has an ASHA CCC or a SCLLR SLP license can refer a child for service that will be given by another provider. There is an inherent conflict of interest in having providers refer to themselves. Medicaid requires that all referrals for school-based services

15 Page 15 of 18 be done by someone other than the provider this is true not just for Speech, but for OT, PT, O&M, etc. SUPERVISION/UNDER THE DIRECTION OF 45. QUESTION: Is there a set number or maximum number of nonstate licensed (i.e. SDE-certified speech therapists) that SLPs with SC LLR licenses can supervise? ANSWER: SC LLR limits only the number of licensed SLP Assistants an SC LLR SLP is allowed to supervise. The SC LLR code allows an SLP to supervise 3 part time and 2 full time SLP Assistants. SC LLR imposes no limit on supervision of SCDE certified speech therapists. SC LLR follows the SC SLP Code, and the supervision of SCDE speech therapists are not addressed in the code. 46. QUESTION: Can a Clinical Fellowship Year (CFY) person bill Medicaid without supervision? ANSWER: Yes, this person meets the Medicaid SLP program staff requirements as indicated in the third bullet of page 2-25 of the LEA Medicaid Manual. For purposes of billing Medicaid, a SLP must meet one of three requirements have a certificate of clinical competence (CCC), have completed equivalent educational and work requirements for the CCC (defined as the SC LLR SLP license), or have completed the academic program and is acquiring work experience to qualify for the CCC. This last designation is referred to as the CFY and the individual in this status is supervised as part of the CFY requirements. Thus, additional supervision is not necessary for purposes of billing Medicaid. 47. QUESTION: Can the supervisory forms samples be provided online, electronically or on disk for us to use when revising for our own districts? ANSWER: All forms will be available via the SCDE Medicaid Office (OSBHF) website at QUESTION: What is the supplemental statement form? Where should this form/documentation be filed? What is the cite or where is the supplemental statement form requirement listed in the Medicaid LEA Manual? Is this form included on the Quality Assurance Checklist that will be used by SCDE Quality Assurance staff for on-site visits?

16 Page 16 of 18 ANSWER: The Supervisory IEP Approval Form (SIAP) is sometimes referred to as the supplemental statement or supplemental statement form. This form is used as a supplemental statement to be signed by the supervising SLP who cannot attend the IEP meeting to document his/her concurrence or approval of the speech services specified in the IEP. This form is used when there is no SLP (as defined on page 2-25) signature on the IEP. That is, the SIAP is necessary if the speech IEP team member who signs the IEP is non-credentialed. SCDE Medicaid Quality Assurance Representatives will look for the SIAP when reviewing the IEP; therefore, it should be filed with the IEP. There is no direct reference to the SIAP in the LEA Medicaid Manual but it is referenced in the Speech Language Services Quality Assurance Checklist. Page 2-29 of the LEA Medicaid Manual requires that the Individual Treatment Plan (ITP) must contain the signature and title of the Speech Language Pathologist and the date signed. The IEP may suffice as the treatment plan as long as the IEP contains the required elements for the ITP (Medicaid Manual at page 2-29). Page 2-25 defines SLP providers CCCs, SC LLR License or Clinical Fellowship Experience. Thus, by inference, one of these three designated provider types must sign the IEP/ITP as required by Medicaid. Given that the SLP may be unable to attend the IEP meeting, the SIAP is used to substantiate the required signature for the IEP/ITP indicating that the SLP concurs with the IEP. 49. QUESTION: Is a supplemental form (stating that the IEP was reviewed and approved) needed for all Medicaid eligible IEPs or only for those IEPs developed by SLT s who are under the direction of a supervisory SLP? ANSWER: For Medicaid billing purposes, SCDE Quality Assurance Medicaid Representatives will look for the SIAP form for Medicaid eligible children, if such forms are warranted. Districts should use their own discretion as to whether or not to have the SIAP forms signed for all students, regardless of Medicaid eligibility. 50. QUESTION: Can the sample statement for the supervisor to sign as a supplement to the IEP be put on the website? ANSWER: All forms will be posted on the OSBHF website at QUESTION: As a private contracting company, we must have LLR License in order to supervise in the school system. However, we can only supervise 2 full-time or 3 part-time assistants/ interns. Are private contracting companies limited to supervising 2 fulltime /3 part-time speech therapists in the school system?

17 Page 17 of 18 ANSWER: The private contracting company must adhere to SC LLR supervision limits as requirements for the SC LLR license. See earlier related question/answer also. Additionally, guidelines set forth in the contract between schools and private contractors must be adhered to. 52. QUESTION: Are we to go back and hold meetings to discuss all IEP s of Medicaid students for the purpose of signing off on those IEP s for the current year ( )? ANSWER: No, it is not necessary to hold meetings to discuss these IEPs. Districts must use the SIAP form where warranted. SCDE QA Medicaid Representatives will look for such form effective with the scheduled onsite QA visit for school year QUESTION: Does this form (Supervisory IEP Approval Form) need to be completed for all IEPs that you serve as the LPHA not just non CCC s people? ANSWER: No. A supervisory level provider needs to sign the IEP. If not available at the time of the meeting, a supervisor can sign a supplemental statement. If you cannot sign at the time of the IEP meeting, another supervisory-level provider may sign, or you may sign a supplemental statement to take care of this requirement. You do not need to sign a supplemental statement for all IEP s over which you supervise. You only need a supplemental statement for the IEP meetings if neither you nor some other supervisory-level provider can attend. 54. QUESTION: Why don t we use ASHA guidelines at all times? ANSWER: ASHA guidelines are just that, guidelines. We seek to harmonize the requirements of CMS, SCDHHS, ASHA and SCLLR related to IDEA and Medicaid requirements. 55. QUESTION: Can a CFY-SLP bill Medicaid unsupervised. ANSWER: Yes, per the LEA Manual at page 2-25, the third bullet defines the CFY-SLP as a SLP for purposes of billing Medicaid. 56. QUESTION: You said a CFY-SLP can bill Medicaid unsupervised. Is that indefinite even if they don t acquire their CCC s after the CFY year? ANSWER: The Clinical Fellowship Year (CFY) may stretch to 4 years under ASHA guidelines, so it s not strictly a calendar year. The CFY-SLP can bill Medicaid unsupervised while acquiring supervised work experience.

18 IEP Supplemental Statement* I was unable to attend the IEP meeting held on for (name of student): Therefore, I am providing a supplemental statement. I approve of the decisions of the IEP team related to the (name of service):, goals and objectives, length, frequency and type (group or individual) as outlined in the IEP. Name and title Signature Date *An IEP Supplemental Statement is needed when a supervisory level provider is not able to sign the IEP at the meeting. Approved by DHHS November 26, 2007