Virginia Regulatory Town Hall View Comments

Department of Behavioral Health and Developmental Services

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 8:18 pm

Commenter: Sandi Harrington, Infant & Toddler Connection of Norfolk

Part C Early Intervention Practice Manual Comments

The Practice Manual & TRAC IT

The Practice Manual, page 2, states: TRAC-IT (Tracking, Reporting and Coordinating for Infants and Toddlers) is Virginia’s statewide early intervention data system. The Practice Manual assumes early intervention steps are being completed directly in TRAC-IT. However, references to “completing” a task in TRAC-IT allow that it may be completed through direct data entry or an electronic health record (EHR) upload.

Since it is expected that “early intervention steps are being completed directly in TRAC IT”, then TRAC IT should be in line with the Practice Manual and vice versa. Currently, the following areas are not consistent:

Declining EI Services form – throughout the Practice Manual, the Declining EI services form is listed as “optional.” This form is not available consistently, or ever as a stand alone form, within TRAC IT and making it an optional form is confusing for staff. References to Declining EI Services can be found on page 11 – 12d; page 35 4a; page 72 – 7c; page 73 - 8a; page 119 -12c and 13 a; page 127 – 17c; and page 128 – 18a. Recommend adding a stand alone Declining EI Service form to TRAC IT or removing completely from the Practice Manual.
Eligibility Determination – if a child is found eligible due to medical records, it is not possible to update the eligibility determination form at the assessment for service planning meeting as described in Chapter 4: Intake and Chapter 6: ASP without requiring the family to sign an additional Notice and Consent for Eligibility Determination. The Practice Manual should reflect processes that are available in TRAC IT. Recommend separating the Notice & Consent for Eligibility Determination and Eligibility Determination form as two separate tasks in TRAC IT to align with the practices described within this draft of the Practice Manual.
Physician Certification letter and IFSP Summary letter as referenced in Chapter 7, page 69, 5b and 5c. TRAC IT does not contain a Physician Certification letter or IFSP Summary letter. Recommend adding both to TRAC IT as it is described in the Practice Manual.
Chapter 9 EI Record, General Rules for documentation page 148 – 7, 8, and 14 – if documentation is completed directly in the record, then handwritten should not be an option for contact notes. Recommend deleting the handwritten option.
Chapter 9 EI Record, Access to Records page 150 – 5; this indicates that a record must be kept on the “Access to Record form” which does not exist in TRAC IT. Recommend adding to TRAC IT as it is described in the Practice Manual.

Errors / Information that is Incorrect/Outdated

Chapter 7, IFSP Instructions, General Information, page 77, 4^th bullet references Section V of the IFSP which is an old numbering system. Should reflect Services section of IFSP. Recommend removing reference.

Chapter 11, Finance, page 187 references ITOTS – should be TRAC IT. Recommend changing reference.

Chapter 11, Finance, Early Intervention Rates, page 162 – incorrect rates for audiologists; page 164 -6 – incorrect EI rate, page 194 – T2022 incorrect EI rate. Recommend updating to correct EI Rate.

Financial Implications

Chapter 4 Intake and Chapter 6 ASP both strongly recommend the use of additional social-emotional screening and assessment tools. While this is best practice, there are direct financial costs in purchasing new assessment materials and training new staff. It would be helpful to have additional funding to support these activities. Recommend changing the language in the Practice Manual or seeking funding to support best practices.

Chapter 7 IFSP Development, page 70 – it is increasingly difficult to obtain physician certification despite multiple attempts to get the IFSP certified due to staffing shortages at the pediatric offices. Recommend removing the restriction from using Part C dollars when good faith efforts are made and documented.

CommentID: 237797