Chapter 4, page 23, item 5.a.4 states "Use of the ASQ-SE or another social-emotional-specific screening tool is strongly recommended for all children, in addition to the comprehensive screening tool, as part of the initial eligibility determination process. It is strongly recommended that no child be found ineligible for early intervention without completing the ASQ-SE or another social-emotional-specific screening tool." Comment: The addition of a required screening tool (ASQ-SE) must be accompanied by additional funding to support purchasing the tool and training staff to use it ."
Chapter 6, page 56, item 4.f states "Strongly recommended: If the ASQ-SE was completed during eligibility determination and results were in the monitoring zone or above the cutoff, the assessment for service planning should include the use of a social emotional-specific assessment tool. ….. It is strongly recommended that the assessment for service planning team includes a practitioner with infant mental health expertise (social worker, counselor, psychologist) or a practitioner with Infant Mental Health endorsement at the Family Specialist Level or higher for those children with ASQ-SE results in the monitoring zone or above the cutoff or when other risk factors are present. : Comment: To meet the "strongly suggested" expectation of completing a specific social emotional assessment tool, local systems will need additional funding to support purchasing a tool and training staff to use it. Further, to include a practitioner with infant mental health expertise or endorsement will require significant investment in personnel preparation. Many communities lack access to such personnel and will not have capacity to meet this expectation. We look forward to understanding the plans for expanding the cadre of personnel who can meet these qualifications and how funding will available to support added staff.
Chapter 7, page 70, Specific requirements related to physician signature states: "if an IFSP is not signed by the physician, physician’s assistant, or nurse practitioner within 30 days of the first IFSP service other than service coordination, then services provided prior to the date the IFSP is certified (by the physician, physician’s assistant, or nurse practitioner) will not be reimbursed by Medicaid or Part C." Comment: Local systems are hampered in meeting this requirement by families who can't afford to or choose not to take children to the pediatrician and pediatricians refusing to sign if they haven’t seen the child within a specific period of time. We are required to provide the service but unable to access reimbursement regardless of how much we encourage the family to take the child to the pediatrician. Part C funds should be available to support services with documentation of effort to acquire physician certification.
Chapter 9, page 148, General rules for documentation #13 states: "Complete contact notes and enter/upload notes to TRAC-IT in a timely manner, no more than 5 business days from the time of the contact." Comment: Local systems using monthly data uploads are unable to meet the expectation of entering or uploading documents within 5 days. Please consider language that continues the allowance for less frequent data uploads.
Chapter 11, page 162, Early Intervention Rates. Comment: Two references to a rate of $168.75, correct rate is $168.76
Chapter 11, page 162, Early Intervention Rates. Comment: Published rates are insufficient to sustain a quality workforce. Recommend a comprehensive rate study that results in increased rates with a plan to review adequacy on an annual basis.
Chapter 11, page 164, Application of Rates. Comment: Three references to a rate of $168.75, correct rate is $168.76.
Chapter 11, page 187 Comment: Reference to ITOTS, should read TRAC-IT
Chapter 11, page 194 Comment: T2022 correct rate should read $148.50