In various places, services are referred to as counseling sessions and that does not always capture what staff are providing. I would recommend using services consistently.

When referencing diagnosis, please consistently include 'or clinical impressions' throughout the document.

In the unplanned services section of Chapter 6 the bullets listed should be under the mental and behavioral health services. Those items would not be captured in unplanned services. 

there has been a great internet usage and the prices are sky rocketing.

192.168.1.1 login is getting important. 

IANA, i.e. the Internet Assigned Number Authority, has kept aside a set of IP Addresses for various reasons, including the creation of a dedicated address for logging into your router’s control panel.

Typically, 192.168.1.1 is the IP address for a router’s login page - once the user enters their username and password, the page redirects to the settings and configuration page.

The problem is that most people get it wrong on the first try because of human error and maybe even auto-correct suggestions - they end up entering 192.168.l.1 Instead of 192.168.1.1.

This is because the number “1” and the letter “l” look quite alike, so when people read out the IP address on screen or from the router’s box, they tend to interchange the two.

Chapter VI of the updated LEA manual now states that “Student progress or service logs that... are completed as soon as possible, but no later than 30 days from the date of service;” As a school based administrator, I have concerns about how this will impact our providers. We use a vendor for Medicaid reimbursement and our providers are required to enter in their documentation monthly. If a time frame is required, could it be placed at least 45 days for signatures from the service delivery? If the 30 day requirement is kept, our providers will have to maintain two sets of documentation to “prove” that they have documented the service within the 30 days and the electronic version of the documentation, which could prove problematic during IDEA due process situations. All Medicaid documentation is, at its core, data entry from the clinical documentation that a therapist maintains during therapy sessions. Divisions that use a vendor will now be held to a stricter standard as there is back-end documentation on when a service is entered and signed.

Additionally, there are 1-year timely filing requirements. If a school division finds out in March that a student is now eligible for reimbursement beginning in January (and they are only requiring their providers to provide documentation on Medicaid eligible students), they will miss out on any potential back billing because of this 30 day signature requirement.

Additionally, LEAs operate differently than medical and private therapy settings. Missed days due to holidays, snow days, extended leaves due to natural disasters, etc. could impact a providers’ ability to sign documentation within the 30 day guidelines. 

Currently, it is acceptable for Certified Occupational Therapy Assistants, COTAs, and Physical Therapy Assistants, PTAs, to become licensed and provide direct therapy under the supervision of fully licensed practitioners. However, it isn't acceptable for Speech-Language Pathology Assistants, SLPAs, to practice.  All three require at least an Associate's degree and supervision. It is becoming difficult to hire Speech-Language Pathologists, especially in a school system. Allowing Speech-Language Pathologist Assistants to become licensed in Virginia and to provide direct services would be of great benefit to better serve our patients. 

Throughout the different chapters there are inconsistencies to how certain qualified provider groups and services are referenced. Please consider using consistent terminology and phrasing throughout. 

In all draft LEA chapters, the Mental/Behavioral Health sections do not provide consistency in terminology and are hard to understand the expectations of the requirements. Chapter 6 specifically is extremely confusing with the layout of expectations/documentation requirements for planned versus unplanned services.

I also have serious concerns about the 30 day signature requirement for Medicaid documentation. There are multiple factors that could impact a provider's ability to enter and sign electronic documentation (typically impact school divisions using documentation vendors) within a 30 day window including but not limited to their caseload sizes, service delivery models of IEP services (no built in time or appropriate settings to enter electronic documentation), retroactive eligibility (school divisions only get quarterly snapshot Medicaid eligibility), etc.  I understand that this is often best practice from a clinical perspective, but I have reservations about it due to the practicality behind school service delivery and documented.