Policy & Procedure Letter Round Up
Over the last few weeks, DHCS released several Policy & Procedure Letters (PPLs), and more are expected to be published soon. Paradigm has summarized the latest PPLs below and emphasized important aspects in bold.
PPL 21-016 — Contractor Enrollment in Medi-Cal to Provide Services Under the LEA Medi-Cal Billing Option Program.
Released on July 30, this PPL confirms that all contractors providing telehealth or in-person services no longer need to enroll as a Medi-Cal provider, as long as the district has established a reassignment of right to bill with the independent contractor as well as the contracted agency. The only instance an individual provider participating in the LEA Billing program is required to enroll as a ‘Medi-Cal Provider’ is if they order, refer, or prescribe services. The latter is well established and in practice with California schools.
PPL 21-017 — Alternate Format Request Requirements
This is additional DHCS communication for ensuring compliance with ADA. Through this PPL DHCS notifies LEAs of their responsibility to comply with the ‘alternate format’ ADA guidelines ensuring accommodations for qualified students and program participants based on their needs. DHCS also sent an amended PPA that is required to be signed by all LEAs by November 1, 2021. Paradigm will provide to its clients the PPA amendment and further instructions in the coming weeks.
PPL 21-018 — Annual or Triennial Individual Education plans (IEPs) and Individual Family Service Plans (IFSPs)
Clarifies that a delay in IEP/IFSP assessments (e.g., triennials) does not impede the LEA from billing for treatment services as long as the treatment service is consistent with the existing IEP/IFSP. This PPL goes on to also confirm that this remains in effect unless a student graduates or ages out, or the IEP/IFSP is terminated or amended to reflect this determination. This is great news, and LEAs can rest assured services provided can continue to billed even if there is a delay in the annual review or triennial assessment under IDEA timelines. We appreciate DHCSs understanding that these delays occur, and ongoing support for students should not be impacted due to this.
