EI CO Response to COVID-19 UPDATED 6/24/20 at 7:00 AM

  • ANNOUNCEMENTS UPDATED 06/11/2020
     
    •  All EI services will continue to take place virtually through at least July 2020. No in-person visits for children with an Individualized Family Service Plan (IFSP) are authorized or funded as an EI service by EI Colorado.
     
    • Access the Early Intervention Colorado Safer At Home Frequently Asked Questions document in both English and Spanish for more information. 06/11/2020
             To Access Spanish Version, Click here   

           
  • Questions regarding Telehealth Updated 4/21/20
    Access the TELEHEALTH PADLET HERE for resources
    Access the TELEHEALTH TRAINING here

    Can EI Services be provided via telehealth without adding it to the IFSP?
    • EI services may be delivered via Telehealth during this time without adding it to the IFSP or data system, if it is not already on the plan. It would be advisable to add Telehealth as one method of service delivery when developing initial or annual IFSPs, or conducting a periodic review.
    Can IFSP Meetings be conducted via Telehealth or phone?
    • IFSP meetings must be conducted virtually by telehealth, or by phone if preferred or necessary. 4/1/20
    Must Providers take the Telehealth training prior to conducting a Telehealth session?
    • Providers are still required to take the Telehealth training, however, the requirement will be waived when there is a need for services to be provided via Telehealth prior to training being completed for reasons outside of their control. This includes problems with registration or website issues.  For resources to get started Providers can view NCHAM's TI 101 training (http://www.infanthearing.org/ti101/), with the expectation that when possible, the Provider will complete Colorado's training. Providers can also go to the EI Colorado Telehealth Facebook page as a Community of Practice where Providers can connect with other providers who are using telehealth.
    Can OTs and PTs bill Medicaid for Telehealth?
    • HCPF has confirmed that OT, PT, and SLP may be provided through Telehealth for private providers not associated with a home health agency. When billing Medicaid for Telehealth, the location of 02 (remote) instead of 12 (home) will be used. This is ongoing (not specific to Coronavirus) and only for services provided in conjunction with an IFSP, Please access the HCPF website for more information https://www.colorado.gov/pacific/hcpf/COVID
    We are not able to utilize Zoom for everyone because we have limited accounts. It is our understanding that facetime and texting is not HIPAA compliant but can we go ahead and use this for the time being and just avoid using personal identifiable information during the exchanges?
    • We are considering additional guidance around alternate modes of service delivery. For now, we encourage CCBs to consider other options. One recommendation is to investigate using Doxy.me as an additional platform. It is also HIPAA compliant and free.
    If a provider is unable to have telehealth sessions because schools are closed and children are home with the provider, is it OK to have a "substitute" provider?
    • Yes, as long as all involved are in agreement (primary provider, CCB, family).
    Can providers conduct telephone sessions if the family does not want or cannot participate via Telehealth?
    • Yes, this is an option. It would be allowable for a 1 hour session to be broken into two 30-minute sessions. Shorter check-ins would also be allowed.
    Providers are able and ready to do telehealth and phone visits for services and meetings but have still had lots of cancellations because SCs and/or families are not ready/able. Is there any support to help those new to telehealth, like families and service coordinators, get up and running?
    • Yes, EI CO is in the process of providing additional support to both CCBs and Providers on virtual visits to families.
    How are interpreters supposed to interpret when there's a telehealth visit?
    • Interpreters can also participate virtually.
    Should a provider do Electronic Visit Verification (EVV) for a telehealth visit? 4/21/20 Can teleheath sessions be provided while a child is in a childcare setting? 4/3/20
    • Yes.
    How are providers talking to families about considering using telehealth? 4/3/20
  • Referral, Evaluation and Child Find Questions Updated 5/26/20
    Access the Checklist for Performing Early Intervention Evaluations Document here 5/13/20

    Resources added 5/27/20


    Since schools are closed/may be closed, can we extend EI services past age 3 until schools reopen?
    • No, EI CO does not have a mechanism in place to provide services past a child's 3rd birthday.
    Is there anything in place for Child Find to evaluate new children (New referrals)? 4/2/20 If school districts close and Child Find teams are not able to work, will CCBs be expected to pick up the evaluations not completed by the AUs? 3/23/20 What is the extended timeline for those whose evaluations we can not complete within the 45 days? 3/25/20
    • The timeline is not extended. Please use the new datasystem code "Sys - National Disaster/Pandemic" to note the reason that the evaluation was not completed within 45 days.
    Can we offer a private evaluation (with our own teams) even if we surpass the 45 day timeline until we figure things out with the school district? 3/25/20
    • Yes, CCBs can conduct evaluations that an AU is unable to complete, even if they surpass the 45 day timeline.
    Will the new system late reason impact our CCB performance profiles? 3/25/20
    • We are awaiting additional federal guidance for data reporting.
    May evaluation or assessment procedures can be completed over the phone? 3/26/20
    • The preferred method for evaluation activities is Telehealth, however, if this is not possible evaluation activities can occur over the phone.
    Can children who have a feeding concern be evaluated through virtual means? 4/1/20
    • Yes. Children with feeding concerns can be evaluated virtually by a provider with expertise in this area.
    Does the in-person restriction also pertain to all screenings and evaluations?
    • Yes. Early Intervention Colorado is discontinuing in-person visits for children and families referred to, or enrolled in, early intervention services.
    Should we discontinue or postpone initial IFSP meetings where a family and child assessment are required to be conducted?
    • No, whenever possible, meetings should be held through teleconference or phone conference with the required participants
    What tools can providers use to conduct a virtual evaluation? 4/10/20
    • At this time any tool that an evaluation team is using effectively can be used to conduct evaluations virtually.
    Can EI funds be used to purchase toys and manipulatives for a family so that they can be used during a virtual evaluation? 4/10/20
    • No, the family should be supported in identifying household items that can be used to assess the skill.
    Should we send the hearing and vision checklists to parents prior to the evaluation? Or should the evaluation team be asking these questions? 4/16/20 
    • Yes. Send the questionnaires to the parents prior to the evaluation. The questionnaires must be reviewed during the evaluation. If the parent doesn't return the questionnaires, then the evaluation team would incorporate these questions during the evaluation.
    Are the evaluation/assessment pages of the IFSP an appropriate place to document the information to inform next steps and the follow up plan for hearing and vision screen? 4/16/20 
    • Yes, the follow up plan for vision or hearing can be documented on the IFSP. 
    Should we develop a follow up plan just when there are concerns around hearing and/or vision, or for all children evaluated? 4/16/20
    • Any child who has not received a formal screening during this time, should receive one when in-person interaction is allowed. Children for whom a concern has been identified should be prioritized for formal screening when this becomes possible.
    Who will pay for the evaluation tools and training that CCBs will need to conduct evaluations? 4/21/20
    • EI Colorado will provide any needed evaluation tools to the CCBs. Please contact Laura.Merrill@state.co.us to request information on training and purchasing of tools.
  • HIPAA compliance questions Updated 5/1/20
    If we are unable to access a HIPAA compliant platform to provide services virtually can we utilize other platforms?  3/23/20
    • The U.S. Department of Health and Human Services has issued guidance related to the good faith provision of telehealth during the COVID-19 nationwide public health emergency. Popular applications that allow for video chats may be used including Apple FaceTime, Facebook Messenger video chat, Google Hangouts video, or Skype to provide telehealth without risk of noncompliance with the HIPAA rules. Additionally, FERPA requirements should not be a barrier to the provision of services. Check with your professional organizations for additional guidance on this topic.

    What is expected of providers who are working with interpreters who are with/near others (not protecting confidentiality)? 4/1/20
    • During this time, it may be difficult for a provider or a interpreter to adhere to the highest standard of confidentiality This should be explained to the family to ensure they understand and agree. If a provider feels that a service may not be provided effectively they may end the session.
    Does EI Colorado have a protocol for notification in the case of potential exposure to COVID-19 for staff, providers or families? 3/23/20 
    • No, CDHS/EI Colorado is not requiring anything beyond the CDC guidelines. Follow the CDC guidelines and your internal practices.
    Even though the teletherapy visits are going well with some families, I think it is fair to say that all of the EI providers are going to take a hit financially. This affects our ability to pay for all of our insurances. I wonder if we still need to have the Privacy insurance? 5/1/20
    • Yes
  • Billing Questions complete section UPDATED 5/1/20
    Please explain when the $10 fee may be billed for Telehealth. 
    • A provider can bill their in-person rate plus $10 using the telehealth code in alignment with the number of visits indicated on the IFSP. If the IFSP indicates 1 hour visit per week and that visit is broken into multiple segments, the $10 can be billed only once, and is allowed to be billed under EIST for direct services, not for meetings. For evaluations and co-visits per provider. 5/1/2020
    When is the $10 telehealth fee not billable?
    • For visits conducted over the phone.
    • For Trans Team meetings
    • IFSP reviews 5/1/2020
    • For no-shows
    Is telehealth billable to private insurance? 
    • The provider will need to check with the specific insurance/plan to determine if telehealth visits are allowed. Private insurance plans that are in the EI Services Trust cover telehealth visits.
    How do I bill for IFSP services completed via a variety of methods (telehealth, phone, email, text, etc.) that occur over a time span? Can the provider and family change the frequency of the IFSP sessions?
    • Medicaid enrolled: Bill the time spent via telehealth to the CPT code. One unit of Parent Ed can be billed to SFG as long as total visit time does not exceed the time documented on the IFSP. For phone or email visits, bill the service in the EI data system by checking the Medicaid denial box and indicating the type of visit in the comments section. 4/21/20
    • Not Medicaid enrolled: Direct service providers should be contacting families at least as frequently as documented on the IFSP for children and families engaged in services. Services provided over a period of time via telehealth, phone, email, text can be bundled into a single visit with the date of service being the initial date of contact. If the bundled services do not add up to the full time duration documented on the IFSP, the full session may be billed up to the amount documented on the IFSP. If telehealth visits are provided for more frequent, shorter time periods the additional $10 telehealth fee may be billed only once for the session frequency documented on the IFSP. Total amount of time cannot exceed the time documented on the IFSP.
    How should a provider bill for services provided via telehealth, phone or email if they are not billable to Medicaid?
    • A provider would bill the same way they would bill for an in-person visit up to the amount of time documented on the IFSP. This includes co-visits and visits for multiple children within the same home. For transdiciplinary team meetings, providers may bill for their time spent during the meeting.
    Which activities conducted by a provider would not be billable?
    • Providers may not bill for any activities completed outside of the direct service provided. Such as any extra time spent in pre-meeting prep and post meeting follow up and writing treatment notes.
    How much detail should providers include when documenting the method of service delivery? 4/21/20 
    • Progress notes should document the method of service delivery. No additional information is needed for billing. The $10 fee is paid by either State or Trust. Independent providers should use the term "telehealth visit" in their treatment notes. Each visit should have its own treatment note.
    How are utilizations for telehealth and phone visits entered into the EI Data System?
    • Utilizations for telehealth and phone visits would be entered the same way as you would for any direct service visit. The $10 Telehealth fee is billed as "session other" on the same utilization as the direct service activity. Enter the amount/flat fee of $10, units =1.
    Can Medicaid be billed for Interpreter services?
    • Interpretation is not a Medicaid billable service.
    Can a service coordinator participate in IFSP meetings via telehealth and bill TCM for it even if they don't have signature pages yet?
    • If the child is enrolled in Medicaid and also is eligible for EI, then TCM activities may be billed.
    Will providers be reimbursed for in-person visits that occurred the week EI CO suspended in-person visits across the state?
    • Yes. Those visits are billable
    The following are questions that have been asked, and they are addressed in the Frequently Asked Questions document on the HCPF website.
    Scroll down the the FAQ section, click there then scroll down to the EI Providers section,

    Please check back frequently as updates are made regularly. https://www.colorado.gov/hcpf/provider-telemedicine  4/16/20
    • Do providers need to change billing codes when billing for services through Medicaid now that providing telehealth?
    • Is the GT modifier used for billing Medicaid for a telehealth visit?
    • Do we need to update the PAR to reflect teletherapy this or will Medicaid let us bill teletherapy without changing the PAR.
    • Can providers bill Medicaid for phone sessions?
    • If an IFSP is conducted virtually, then the hard copy mailed to the parent, this impacts the timeline for obtaining PARs. Will this timeline be waived for the time being?
    • Should a provider do Electronic Visit Verification (EVV) for a telehealth visit?
    • Can OTs and PTs bill Medicaid for Telehealth?
    • Can Home health care agencies bill for Telehealth?
  • Documentation, Process and IFSP Questions UPDATED 6/1/20
    If we happened to do an initial or annual IFSP over phone conferencing can we still do the FA or should the family decline?
    • Yes, conduct an abbreviated Family Assessment over the phone.
    Must the telehealth consent form be signed by the parent before a provider can have telehealth visits?
    • No   4/1/20
    How are signatures obtained on all EI Forms if electronic signatures are not possible?  3/25/20
    • SC documents on the signature line of the document "verbal consent obtained from {mother/father/caregiver} {person's name} on {date} by SC {initials} on {date}. Verbal consents are due to the COVID-19 restrictions for the duration of the COVID-19 emergency."  This will meet the criteria for consent or participation. UPDATED 6/1/20
    Are providers able to text our notes/strategies to parents? If there is not identifying info and then we delete the photo and the text?
    • Yes
    What is the guidance on if we have SC shortages, and need/want to hire or onboard people how do we do that? 3/23/20​​​​​​
    • Follow the typical process for hiring staff. It may be challenging to onboard new staff virtually, however, more and more resources are being developed that address this.  Access this document on Tips for virtual interviewing
    What about make-up sessions for missed visits?
    • Depending on the circumstance it may not be possible to offer make-up sessions to families. Once pandemic related services are no longer needed, IFSPs will be reviewed and services adjusted as necessary, including determination of whether compensatory services are needed. 4/1/20
    Is email an allowable method for IFSP meeting participation? 3/25/20
    • It is not allowable to participate in an IFSP meeting by email.
    Do we need Telehealth consent forms for phone/email visits? 4/1/20
    • No. 
    May a provider or service coordinator consult with a family via email? 3/26/20
    • Yes as CDHS/EI CO has determined that face to face services will not be provided at this time, the EI provider or service coordinator may consult with the parent through telehealth or other alternative method (such as e-mail or video conference), consistent with privacy interests, to provide consultative services, guidance, and advice as needed.
    If a family chooses to move out of state temporarily (3 months) to a location that is safer, can the provider continue to have sessions via telehealth? 4/1/20
    • Once a family moves out of state they are under the jurisdiction of that state's Part C Program and the provider would need to work through that state's Early Intervention program. 4/21/20
    If a family continues to want services in their home is that allowable?
    • No, Early Intervention Colorado has discontinued in-person visits for children and families referred to, or enrolled in, early intervention services.
    Should providers keep families who are not having telehealth visits on their caseload? 4/10/20
    • For families who have initially declined participation in telehealth service provision as it is on the IFSP, providers may offer to support the family through other ways such as email, phone calls, or scheduled check ins. The family may choose to participate in virtual visits in the future.
    The Telehealth Training references SCs being able to access funding to help get families device and internet access for Telehealth. What is the process for doing that? 4/10/20  What kind of documentation should a CCB have for families who are continuing to refuse any direct services at this time? 5/26/20
    • When SC are providing monthly contacts, If families continue to decline direct services provided via telehealth, then the service coordinator will need to have the family sign/give verbal consent to decline the services on the IFSP. The IFSP should be updated to reflect the frequency and method of services the family and child are currently receiving. The Declination of Services form will also need to be completed and the family can indicate whether they want to continue with service coordination only or decline participation in the Early Intervention Program.
    If a family declines Telehealth visits, is it ok to fill out the Justification for Services page of the IFSP to allow for the family to receive in-person/clinic based services for services listed on their IFSP (regardless of the funding source)? 5/27/20
    • No. If a family declines to receive their EI services via Telehealth at this time, they are declining the Early Intervention Service on their IFSP. If a family chooses to have clinic based services they may, but EI CO will not be responsible for the cost of those services.
  • Parent resources
Check back for more information

Make sure you are getting your information from an accurate source such as the Centers for Disease Control  and Prevention (CDC) or the Colorado Department of Public Health and Environment (CDPHE), which are updated regularly and provide valuable resources and information.