Very pleased to see that telehealth / telephonic services will continue! This is a great change and much needed.
Please consider changing the unit of service to 15 minute increments for improved accuracy. At a minimum, please provide specific guidance on how to bill in 1 hour units when services are often less than or more than 1 hour.
Consider changing the 180 day limit on initial SAs to annual.
Clarify quarterly report due dates. Do the dates align with the ISP or when TC services were approved and started?
Clarify "in-kind paperwork" please. The addition of specific requirements for quarterly reports to include graphed data, etc. (which I support), it should be billable.
Will the SIS be made available via WaMS if it is a requirement that TC providers have a copy of this? If not, would the TC provider's assessment, which should be "age-appropriate" suffice?