Update on Medicaid Requirements for SLP Service Billing in the Schools

On October 18, 2016, Clarification Regarding Record Requirements for Therapy Services in Individualized Education Programs (IEPs) was released by the Illinois Department of Healthcare and Family Services (HFS).  The document can be found in its entirety at https://www.illinois.gov/hfs/MedicalProviders/notices/Pages/prn161018b.aspx.

Questions regarding this notice may be directed to the School-Based Health Services Program in the Bureau of Program and Policy Coordination at 217-782-3953.

The notice provides clarification on the documentation requirements Local Education Agencies (LEAs) must meet when seeking reimbursement for eligible expenditures related to therapy services.  We want to alert you to key points outlined in this provider notice.

1. The written referral specifies a need by making a recommendation for speech and language services, but the rendering practitioner, not the referring practitioner determines the diagnosis, frequency and duration of services to be provided.
2. Referrals for speech and language services can be made by a physician or other licensed practitioner of the healing arts acting within the scope of practice. Examples of other licensed practitioners that can refer speech services in the school setting include, but are not limited to, physician assistants, advanced practice nurses, clinical psychologists, speech-language pathologists or individuals with a Professional Educator License (PEL) endorsed in School Psychology or Speech Language Pathology.
3. The referral of services provided in the school setting are subject to provisions of the Health Care Worker and Self-Referral Act (225 ILCS 47/1).
4. The prescription/order or referral is required prior to services being rendered and must be updated annually.
5. The written prescription/order/referral must be included in the student’s file and be made available to the Department upon request.
6. Neither the attendance sheet from the IEP meeting nor the signed IEP itself satisfies the requirement for a written prescription/order or referral.

Please work with your local school district or cooperative to determine procedures related to obtaining the needed referral, as well as what your LEA requires for documentation of the referral.  ISHA is aware that there are questions and concerns regarding recommendations of billing companies regarding if the referring and rendering practitioners can be the same person, and ISHA is making inquiries into this area. We will post more information as it becomes available.