Virginia Regulatory Town Hall
Agency
Department of Behavioral Health and Developmental Services
 
Board
State Board of Behavioral Health and Developmental Services
 
Guidance Document Change: The Department of Behavioral Health and Developmental Services is proposing revisions to the Infant & Toddler Connection of Virginia Practice Manual to address these topics: implementation of Virginia’s new statewide early intervention data system, TRAC-IT; use of telehealth in early intervention; new national guidance/clarifications; clarifications requested by early intervention providers; and newly recommended social-emotional screening and assessment practices. Chapters 3-9, 11-12 and the Glossary include updates to reflect Virginia’s new statewide early intervention data system, TRAC-IT, and the resulting shift from paper forms and/or the old data system, ITOTS, to online data entry in TRAC-IT. Other chapter-specific revisions include the following: 1. A note about references to TRAC-IT in the Practice Manual has been added on page 2 to explain that references in the Practice Manual to TRAC-IT data entry are not a complete guide or manual for using TRAC-IT or for all required data entry. 2. Revisions in Chapter 3 – Referral: VISITS links, contact information and procedures have been updated on page 16. 3. Revisions in Chapter 4 – Intake: An explanation of new Medicaid coverage types was added on page 19. Procedures for collecting race/ethnicity were updated on page 20 to align with new federal guidelines. New recommendations for social-emotional screening were added on page 23 to support early identification of delays or concerns in this area of development. 4. Revisions in Chapter 5 – Eligibility Determination: Changes on page 43 clarify that CMV and toxoplasmosis automatically qualify a child for early intervention if symptomatic, to ensure consistency with the definition of “congenital infection, symptomatic” on page 40. 5. Revisions in Chapter 6 – Assessment for Service Planning: Two new recommended family assessment questions were added on page 55 to help the IFSP team better understand the child in the context of their family as the team, including the family, considers IFSP outcomes and services that will increase the family’s competence and confidence to help their child develop and learn. On page 56, recommended social-emotional screening and assessment practices were added to support early identification of delays or concerns in this area of development. 6. Revisions in Chapter 7 – IFSP Development: Information about virtual IFSP meetings and telehealth service delivery was added on pages 65-67. Consequences of not receiving a timely physician certification for the IFSP are now delineated on page 70. The new wording explains existing policy that was not previously included in the manual. Changes on page 72 update the steps to take when documenting a family’s decision not to receive a service(s) recommended by other IFSP team members. 7. Revisions in Chapter 8 – IFSP Implementation and Review: Recommended practices for ongoing social-emotional screening was added on page 108 to support early identification of delays or concerns in this area of development. Consistent with the revisions in Chapter 7, pages 118-119 and page 127 update the steps to take when documenting a family’s decision not to receive a service(s) recommended by other IFSP team members. Additional language on page 137 clarifies expectations for actions and documentation when the local school division does not respond or fails to attend the transition conference. This wording was added to ensure alignment with updated federal guidance documents. 8. Revisions in Chapter 10 – Dispute Resolution: Revisions were made on pages 154 and 157 to align the timing for signing a confidentiality pledge in mediation with federal requirements. 9. Revisions in Chapter 11 – Finance and Billing: Early intervention rates were updated on pages 162, 190 and 194 to reflect a January 1, 2024 Medicaid rate increase. An explanation of new Medicaid coverage types was added on page 180. Telehealth service delivery and billing requirements have been added on pages 181-182 and mirror the requirements already in place and specified in the DMAS Provider Manual: Telehealth Services Supplement. 10. Revisions in Chapter 12 – Personnel: The list of online modules required for early intervention certification was revised (page 196) to include Authentic Assessment, which has been required for many years but had not yet been added in the manual.
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11/19/25  7:57 pm
Commenter: Kathy Pierson, ITCNRV-Radford University

Part C EI Practice Manual Comments
 

Chapter 6, public comment version page 56, 4,f: Specific Language: 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 whose ASQ-SE results in the monitor zone or above the cutoff or when other risk factors are present.  Comment: The "strongly suggested" expectation may be difficult for rural areas with limited provider options-thus potentially effecting timelines to complete assessment/IFSP.  We typically determine ASP teams based upon a family's concerns and priorities.  Example: If the concern is feeding we would have an OT or ST plus an Early Intervention Professional-who is an employee of the LLA.  It will be an additional expense to local systems for children who have private or no insurance to bill.  

We currently have an OT and DS who have other education, training and experience in supporting children's social/emotional development.  I would recommend making the practitioner guidelines broader. 

Chapter 7, public comment version page 70, Specific Language: If an IFSP is not signed by the physician, physicians assistant or nurse practitioner within 30 days of the first IFSP service other than service coordination, then the services provided prior to the date the IFSP is certified, will not be reimbursed by Medicaid or Part C.  Comment.   Many families can't afford or choose not to take their children to the doctor even after much encouragement from service coordinators.  Doctors will not sign the IFSP if they haven't seen the child within a specific timeframe.  While making attempts to get the the physician cert signed, Part C funds should be available to reimburse contracted providers.  They will not provide  the entitled service for free or may want to wait to begin services until after the physician cert is signed, thus potentially going over the 30 day timeline to begin services. 

Chapter 9, public comment version page 148, Specific Language: 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 uploading documents within 5 days.  Please consider language that continues the allowance for less frequent data uploads.  

 

CommentID: 237793