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School Health Services ProgramDepartment of Health Care Policy and Financing (Department)

Annual Training – Compliance

Summer 2020

www.publicconsultinggroup.com

Agenda

Introduction

Comprehensive Reviews

Licensure Requirements

Potential Findings and Next Steps

Resources and Reminders

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Introduction


AcronymsAcronym Full Names

ASHA American Speech-Language-Hearing Association

BACB Behavior Analyst Certification Board

BCBA Board Certified Behavior Analyst

CAP Corrective Action Plan

CCC Certificate of Clinical Competency

CDE Colorado Department of Education

COTA Certified Occupational Therapist Assistant

DO Doctor of Osteopathy

DORA Department of Regulatory Agencies

FTP File Transfer Protocol

IEP Individualized Education Program

IFSP Individualized Family Services Plan

LPN Licensed Professional Nurse

MAC Medicaid Administrative Claiming

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Acronyms ContinuedAcronym Full Names

MD Medical Doctor

PT Physical Therapist

PTA Physical Therapist Assistant

MTSS Multi-Tiered Systems of Supports

NCSP Nationally Certified School Psychologist

NP Nurse Practitioner

NSPCB National School Psychology Certification Board

OT Occupational Therapist

PCG Public Consulting Group

RN Registered Nurse

SHS School Health Services

SIT Strategic Intervention Training

SLP Speech Language Pathologist

SLPA Speech Language Pathologist Assistant

SPA State Plan Amendment

SSP Specialty Services Provider5


Interactive Instructions

Log into the following Poll Everywhere website: PollEV.com/schoolhealth731

You should see a screen that displays “Waiting for schoolhealth731's presentation to begin…”

Once PCG activates a question, you will have an opportunity to respond by clicking on the answer of your choice

Your answer will be anonymous and can be changed by selecting ‘Clear last response’

PCG will refresh the PowerPoint to display all responses received and facilitate a discussion around the correct answer

Comprehensive Reviews


Comprehensive Review Overview

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Comprehensive Reviews for each participating district examines costs and ratios reported for the most recent certified annual cost report and one quarterly MAC cost report

Districts are responsible for providing requested documentation by the due date given in the notification email

Districts have the option of requesting an entrance call to clarify documentation requirements and answer questions

The validation will include a review of information certified by the district in the PCG Claiming System, direct medical credentials for the period selected for review, and IEP/Other plans of care documentation for the period selected for review

Upon completion of the review of this information, a summary report will be provided with the results of the review. If errors are identified, districts must correct the errors in the PCG Claiming System


Documentation RemindersDocumentation without the below items will result in additional follow up:

• Payroll

• Fund/account codes

Dates of service (Annual)/Paid Dates (MAC)

Salary and benefits broken out separately

•

•

• Direct Medical Other Costs

• Do not necessarily need the receipt if the name of the item, fund/account code, and purchase price are listed on the report

• Licensure

• Please ensure to submit licensure that covers the time the provider was on the SPL during the fiscal year

• IEPs

• Please ensure to submit IEP documentation that covers the selected dates of service

*Other plans of care will be reviewed starting with the FY 2021-22 reviews

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Historical Findings

1

2

1

33

1

11

6 6

44 4

3

22 2

5

1

22

5

3

4

0

2

4

6

8

10

12

FY 2016-17 FY 2017-18 FY 2018-19 FY 2019-20

Nu

mb

er

of

Dis

tric

ts

Fiscal Year

Licensure Annual Cost Reporting

MAC Transportation

General and Statistical IEPs, Attendance, Billing

Direct Medical Other Costs

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What is Reviewed?The Comprehensive Review examines all areas of the SHS program

• As a result of the Comprehensive Review, additional steps and/or training may be required.

Payroll costs

All transportation costs

Service logs

IEPs and/or other medical plans of care

Direct medical other costs (receipts/invoices)

Licensure

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Free Care Other Medical Plans of Care

After the implementation of Free Care, districts/BOCES will be asked to provide medical plans of care for students in addition to IEP/IFSP documents

Medical Plans of Care Examples

IEPs/IFSPs

Health (meal modification,

seizure allergy

management,etc.)

Behavior Safety MTSSThreat

Assessment504

• Only plans that have medical necessity established and scope, frequency and duration will be considered compliant

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Timeline

8

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Notified via email that the district

was selected

District gathers required

documents and

uploads it to the FTP

site

PCG validates

the documents and sends

any necessary follow up questions

to the district

Results are sent to the

Department for review

District is sent their Summary

Report containing the results

of their review

Districts will receive their data request workbook closer to when they complete their desk review• Districts may request an entrance/exit call• Districts will have 20 calendar days from the date on the notification email to

upload the required documentation• The CDE will reach out to selected districts for parental consent forms

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Licensure Requirements


Free Care New License Requirements

As part of the expansion of services, the SPA was intentionally revised so more providers would be eligible in the SHS Program

• For this reason, providers billing Medicaid for services rendered in the greater community will now be eligible for participation if they meet the same license requirements.

How does this impact providers in the SHS Program?

1. Current credential requirements for some providertypes may change to align with

the greater community requirements

2. Additional provider types that exist in the greater community

can be added

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New Provider License Requirements

Provider Type Requirements (must be current)

Applied Behavior AnalystNationally certified as a Board Certified Behavior Analyst (BCBA).

RN, LPN, NP* DORA license; RN, LPN, or registered NP

School Psychologist

Master’s degree or higher, in behavioral, health sciences or education AND one of the following:• licensed teacher with an endorsement of school

psychologist; or• licensed teacher with an endorsement of special education

or early childhood special education; or• Endorsement of school psychology

Supervised by a Doctorate level PsychologistAND

• Have Certification from the National School PsychologyCertification Board (NSPCB)

SLPA

Supervised by CDE licensed or DORA certified Speech Language Pathologists (SLP). SLPs must follow the ASHA guidelines on the training, use, and supervision of assistants. Speech-language pathology assistants must practice under the general supervision of a Colorado registered speech-language pathologist.

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*Only new provider type for nursing services


Updated Current Provider Requirements

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SLP requirements have changed slightly to align with the revised SPA

• These updates will go into effect on October 1, 2020.


SLPMust have a current CDE license or a certification by DORA pursuant to the Speech-Language Pathology Practice Act

SLP Candidate

Candidate must be in his/her clinical fellowship year or have completed all requirements but has not yet obtained CCC Services provided under the direction/supervision of a qualified therapist in accordance with 42 CFR § 440.110(c)

NOTE: Valid through September 30, 2020, ASHA certification is required

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https://www.colorado.gov/pacific/dora/Speech-Language_Pathology_Laws


Current Provider Requirements (unchanged)

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8

There were no revisions to the license requirements of these current providers


Audiologist DORA license or CCC in Audiology from ASHA

Audiologist Candidate

Candidate must be in his/her clinical fellowship year or have completed all requirements but has not yet obtained CCC from ASHA. Services provided under the direction/supervision of a qualified therapist in accordance with 42 CFR § 440.110(c)

Clinical Social Worker DORA license (Clinical Social Worker) - Master’s Level

Counselor / Marriage & Family Therapist

DORA license (Counselor / Marriage & Family Therapist)

OT DORA license (OTR)

COTADORA license (OTA) effective June 1,2014. Services must be provided under the direction/supervision of a qualified OTR in accordance with 42 CFR § 440.110

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Current Provider Requirements (unchanged) Continued

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PT DORA license (PT)

Qualified PTA as defined in 12-41-113 (1) C.R.S., and when PTA

acting under the direction of a Colorado –licensed PT

Physician (MD or DO) DORA license (Medical Doctor or Doctor of Osteopathy)

Psychologist DORA licence (Psychology); Doctoral level

Social Worker DORA license (Social Work); Master’s Level

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Compliance Activity

Potential Findings and Next Steps


Potential Findings

1Calculation of the Specialized Transportation One-Way Trip Ratio Denominator

2Direct Medical Materials and Supplies were reported, but are not used in the provision of a direct medical service

3Salary and Benefit documentation does not align with what is reported in the PCG Claiming System

4 Non-allowable transportation other costs were reported on the annual cost report (Does it make the bus go?)

5Expired licensure or type of licensure does not support the job category listed on the PCG Claiming System

If you have any questions about documentation and allowable costs, don’t ever hesitate to reach out to PCG! PCG should always be your first point of contact!

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Scoring

The Comprehensive Review consists of 12 performance standards if you report transportation costs or 9 if you do not report transportation

• Each standard is graded as either a PASS or FAIL

• For example, if one of the sampled individual’s payroll documentation does not match costs reported in the PCG Claiming System it would be marked as a finding

• The overall score and resulting next steps for each district will be based on the costs reported

8

9

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Scoring RubricScoring

CategoryPerformance Standard

DescriptionRequired

DocumentationPerformance

Rating

1a

No variance in salaried and

contracted documentation

provided and annual cost report

Salaried and Contracted Costs

Pass

1b

No variance in direct medical

other costs documentation

provided and annual cost report

Direct Medical Costs Pass

1c

Licensure provided covers all

time periods individual was listed

on staff pool list and reported

costs

Licensure Fail

1d

No variance in salaried

documentation provided and

annual cost report

Transportation Payroll Costs

Pass

1e

No variance in transportation


annual cost report

Transportation Other Costs

Pass

1f

No variance in transportation


annual cost report

Transportation Equipment Depreciation

CostsPass

9

0

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Scoring Rubric Continued

Scoring Category

Performance Standard Description

Required Documentation

Performance Rating

1g

Documentation provided supports

one-way trip ratio denominator and

transportation services IEP student’s

ratio

General and Statistical

InformationPass

2a

Documentation provided support

claims billed. This includes service

logs

Service logs Pass

2b

Documentation provided support

claims billed. This includes

attendance logs

Attendance logs Pass

2cDocumentation provided support

claims billed. This includes the IEPIEP Pass

3

Contracted/salaried employee costs

provided by the district show no

variance in the claiming system cost

report

Direct Service & Admin.

Payroll/Salaried and

Contract

Pass

4District met the timeline in which

documentation was dueN/A Pass

9

1

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Strategic Intervention TrainingDistricts that receive a FAIL on ANY performance standard will be required to attend a SIT

• SITs will provide additional targeted training on the specific failed performance standard

• It is important and required that the appropriate staff person(s) attend the SIT

• SIT trainings are available to districts throughout the year

9

2

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SITs ContinuedSIT notification and a link to the specific training will be located on the PCG claiming system dashboard

• Contact the PCG help desk, if an individual needs access to the PCG Claiming System to complete the SIT

• You will be asked to complete a short survey prior to being redirected to the training video

9

3

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Corrective Action Plan

Districts who receive a score of 9/12 (6/9 if they do not report transportation) or lower will be issued a CAP

• Districts will receive formal notification of a CAP and additional targeted training on the failed performance standards

• It is up to the discretion of the Department if districts may be selected again for another comprehensive review the following year based on final review results

9

4

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Do

Act

Check

Plan

Resources and Reminders


It Takes a Village

Communication is key

• Each department has a role to play in ensuring that the district has optimized their claiming potential and minimized compliance risks

Business Office

Human Resources

Special Education Teachers

AccountingIEP Team

Coordinators Finance

Transportation

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Program Resources

Free Care resources can be found in the following locations:

School Health Services Program: colorado.gov/pacific/hcpf/school-health-services

PCG Claiming System: claimingsystem.pcgus.com/co

• Free Care recorded Webinars

• Free Care FAQs

• User Guides

• Stakeholder information

• Program Manual

• Program Calendar

• Training schedule

• Newsletters

• Fact Page

• Annual training PowerPoint presentations

• Staff Pool List Decision Tree

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http://www.colorado.gov/pacific/hcpf/school-health-services

https://claimingsystem.pcgus.com/co


Contact Information

If you have any questions, please feel free to contact us!

Department

Marissa Visscher

Email: [email protected]

Phone: 303-866-6328

PCG

Annual Help Desk


Phone: 866-317-0223

RMTS/MAC Help Desk


Phone: 866-766-9015

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mailto:[email protected]



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