EI CO Response to COVID-19 UPDATED 4/3/20 at :45 pm

    Please reference the CDHS-CDE Joint Guidance on Vision and Hearing Screening 4/2/20

    Please reference the CDHS-CDE Joint Guidance on Part C Evaluations During COVID-19 document for current guidance posted 3/23/20

    Early Intervention Colorado has discontinued in-person visits for children and families referred to, or enrolled in, early intervention services.

    Will providers be reimbursed for in-person visits that occurred the week EI CO suspended in-person visits across the state? 4/2/20
    • Yes. Those visits are billable.
    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.
    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.
  • Questions regarding Telehealth Updated 4/3/20
    Access the TELEHEALTH PADLET HERE for resources

    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? 4/3/20 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 and Evaluation Questions Updated 4/2/20
    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? UPDATED 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.
  • HIPAA compliance questions
    If we are unable to access an 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.
  • 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?
    HCPF is working on a solution to this. Please continue to check their Covid-19 updates page: https://www.colorado.gov/hcpf/covid
  • Documentation, Process and IFSP Questions UPDATED 4/1/20
    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 {person's name} on {date}" . This will meet the criteria for consent or participation.
    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
    • No. Once a family moves out of state they are under the jurisdiction of that state's Part C Program.
  • Billing Questions UPDATED 4/2/20
    Can service coordinators participate in IFSP meetings via Telehealth meetings as well and bill TCM for it?   Or can they participate over the phone and bill TCM for it?
    • Yes. Any allowable TCM activity may be billed.
    Will there be a possibility that contract providers can bill or be paid if services need to be suspended or telehealth is not an option for a family?
    • This is under discussion.
    What can a Provider bill for a telehealth session?
    • A provider can bill their in person-rate, plus $10. 
    How much detail should providers include when documenting the method of service delivery? 4/2/20
    • 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.
    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.
    Can we bill TCM for IFSP meetings if we do not have signature pages?
    • If the child is enrolled in Medicaid and also is eligible for EI, then TCM activities may be billed.
    Can home health care agencies bill for Telehealth? Can a provider bill for a telehealth no-show?
    • If the CCB reimburses for no-shows, then their policy would be applicable to a telehealth visit, as well. The $10 additional fee would not be applicable
    We have made a decision in our agency to move all home health visits to teletherapy delivery. Do we need to update the PAR to reflect this or will Medicaid let us bill teletherapy without changing the PAR? Can Medicaid be billed for Interpreter services?
    • Interpretation is not a Medicaid billable service.
    Do providers need to change billing codes when billing for services through Medicaid now that providing telehealth? 3/23/20 Can providers bill Medicaid for phone sessions? 3/23/20 Will the state reimburse $10 for telehealth when it is conducted over the phone and not audio-visual? 3/23/20
    • No. The $10 extra is intended to support providers in paying for the infrastructure to provide telehealth visits.
    How are you supposed to bill the $10 telehealth fee for Transteam meeting attendance in Unicorn (EI Datasystem)? 3/25/20
    • The $10 extra is only for direct services, not for meetings.
    Is the additional $10 for a telehealth visit allowable under the EIST? 3/25/20
    • Yes
    Can providers bill for any extra units spent in pre-meeting prep and post-meeting follow-up? 3/25/20 
    • Providers may not bill for activities completed outside of the direct service provided
    Can we host our monthly transdisciplinary team meetings virtually and have providers be paid for their teaming time? 3/25/20
    • Yes
    How are utilizations for telehealth and phone visits entered into the EI Data System? 3/25/20
    • Telehealth is billed as "session other" on the same utilization as the direct service activity. For Telehealth you enter the amount/flat fee of $10, units =1. Phone sessions are billed as any other direct service activity.
    When complete IFSP reviews or evaluation by telehealth, are providers allowed to bill the additional $10? 3/26/20
    • No
    How much can a provider bill for a session, including writing treatment notes? 4/1/20
    • Up to the amount of time documented on the IFSP.
    If we are billing Medicaid directly- are they re-imbursing extra for telehealth? If not, do we bill the CCB separately? 4/1/20 Is the GT modifier used for billing Mediciad for a telehealth visit? 4/1/20 When providers have multi sibling visits, and parent coaching is working, would it be feasible to do a joint activity and overlap billing times with 2 children? 4/2/20
    • You would bill the same way you would bill if it was an in-person visit.
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.