The unit of service shall be one hour.

Comment: change to 15 minute units for accuracy and quality assurance.

Therapeutic consultation shall not be billed solely for purposes of monitoring the individual.

Comment: Please define “monitoring.”  We were recently pended and engaged in an extensive back-and-forth discussion with Lead PA Consultant due to different interpretations of “monitoring.”  Behavior Analysis requires extensive data collection throughout the development and implementation of the Behavior Support Plan.  Once a BSP is developed, it should be considered fluid, as changes are continually made based on direct data analysis. Data collected after the development of the plan should not be considered monitoring, until the individual has reached discharge criteria.  

Travel time [ , and ] written preparation [ , and telephone communication ] shall be considered as in-kind expenses within therapeutic consultation service and shall not be reimbursed as separate items.

Comment: Please define written preparation as an in-kind expense. What documentation does this include and not include?

The need for this service shall be based on the individual's ISP and shall be provided to an individual for whom specialized consultation is clinically necessary. Therapeutic consultation service may be provided in individuals' homes and in appropriate community settings, such as licensed or approved homes or day support programs, as long as they are intended to facilitate implementation of individuals' desired outcomes as identified in their ISP.

Comment: We have encountered situations where individuals require crisis stabilization and/or hospitalization after Therapeutic Consultation services have been authorized.  In these situations, it is necessary for us to provide therapeutic consultation services in conjunction with these crisis stabilization services in order to support the individual in successfully transitioning back into residential services.  Please include that Therapeutic Consultation may be provided in conjunction with crisis stabilization (either in hospital or crisis stabilization unit). 

Initial SARs will be approved for only 180 days after which point a new SAR will need to be submitted with accompanying documentation including baseline Data.  Annual renewals will need to have an annual summary of quarterly data.

Re-submission of authorization requests after 180 days can and will cause delays in services. 

Telehealth

Comment: Please continue to allow telehealth and phone sessions, as this has allowed us to provide services to many individuals and their teams that would not otherwise have been able to receive services (either due to health concerns or location).