UPDATED: DHCS Clarifies Position, Expressly Allows OT & PT Treatment Services Prescribed by LEA-Contracted Physicians

**Update as of October 2, 2017**

Since this post was originally published, DHCS has extended the 6-month renewal requirement to an annual renewal requirement for OT and PT prescriptions.

The announcement was made in an email from DHCS to LEAs on September 27, 2017, stating: “On August 24, 2017, DHCS sent the above policy update, with an additional requirement that prescriptions for PT/OT treatment plans would be limited to six months. Prescriptions for treatment plans are generally established and documented annually in the student’s IEP/IFSP; therefore, the LEA Program will be held to the IEP/IFSP time period. The current policy, as outlined in the LEA Program Provider Manual, will continue to apply to LEAs: prescriptions for treatment plans must be updated annually and maintained in the student’s files.


**Original article, posted August 24, 2017**

Big news for California LEAs who have been waiting for clarification from the Department of Health Care Services (DHCS) regarding Occupational Therapy (OT) and Physical Therapy (PT) treatment services prescribed by LEA-employed or contracted physicians.

In an email sent to program stakeholders on August 24, DHCS makes clear that prescriptions for OT and PT treatment services may come from physicians employed by or contracted with the LEA. Specifically:

“Prescriptions for PT and OT treatment services, as required by Title 22, California Code of Regulations, Section 51309(a), may come from physicians employed by or contracted with the LEA, or may come from the student’s primary care physician, dentist or podiatrist. A prescribing physician does not need to be the student’s primary care physician, and does not need to personally evaluate the student to issue a prescription for PT or OT treatment services. However, the prescribing physician must have a working relationship with the LEA and treating physical/occupational therapist, and must review the student’s records prior to prescribing services. Prescriptions for treatment plans are limited to six months and must be renewed for medical necessity.”

The use of LEA-employed or contracted physicians to review OT and PT treatment plans, which are prepared by the student’s treating physical or occupational therapist, has been a common practice for years. In light of DHCS’ email, LEAs can continue this practice with the full confidence that it is supported by California regulation and Department policy.

Recently, DHCS had issued guidance stating that the prescribing physician needed to be either the student’s primary care physician or have personally evaluated the student. The state agreed to review that guidance based on feedback from LEAs, which concluded in a reversal of their previous guidance and the policy issued this week that expressly allows OT and PT treatment service prescriptions issued by LEA-employed or contracted physicians.

Read the full DHCS email announcement here.