Welcomed Relief for LEAs in PPL 23-004R
On September 11, 2023, the Department of Health Care Services (DHCS) released Policy and Procedure Letter (PPL) 23-004R, bringing significant changes and welcomed relief for Local Educational Agencies (LEAs) concerning Alternative Format Plans for individuals with speech, hearing, or visual disabilities. This revision came as a fourth iteration of the PPL, following the initial release of PPL 21-017 in 2021.
Background
These PPLs are DHCS's response to the responsibilities that Medi-Cal Providers bear to ensure compliance with state and federal laws, particularly those pertaining to the effective communication of healthcare information to students and individuals served by LEAs, including those with disabilities. These requirements align closely with the accommodations already provided by California public schools to students with disabilities and those with alternative format needs under Section 504 and the Individuals with Disabilities Education Act (IDEA). The goal is to ensure that students and their parents/guardians with alternative format needs can access healthcare information and communications in a format that suits them best.
To facilitate compliance, DHCS has issued directives requiring LEAs, as Medi-Cal Providers, to establish an Alternative Format Plan and related policies. Foremost among these requirements is the creation of policies and procedures that guarantee students with disabilities and their parents/guardians access to student healthcare information and communications in alternative formats, such as large print, audio, or electronic versions, provided at no cost.
The Evolution of PPLs
The journey toward clear guidelines for Alternative Format Plans began with PPL 21-017 in August 2021, which was subsequently refined by PPL 21-017R in December 2021. These initial directives raised numerous questions from LEAs and regional agencies, setting the stage for further development. While these early PPLs represented significant steps in acknowledging the need for accessible healthcare information, they lacked the detail provided by the subsequent PPL 23-004, released in February 2023. Alongside PPL 23-004, DHCS introduced Plan Guidance, offering explicit instructions and clarifications to assist LEAs, acting as Medi-Cal Providers, in effectively meeting their obligations.
Then, on September 11, 2023, DHCS issued PPL 23-004R, which introduced several crucial updates:
No Reporting Requirement: LEAs are no longer obligated to report new alternative format requests made by students back to Medi-Cal. This change significantly reduces LEA workload and simplifies their plans.
LECs Sharing Information: The PPL clarified that Local Educational Consortia (LECs) can now share Alternative Format information with LEAs as part of their lookup process.
Frequent Updates: While the PPL stipulates that LEAs must receive Alternative Format information quarterly, Paradigm LEA Billing clients will have immediate access to the most up-to-date information through our monthly eligibility lookup service. This eliminates the need for LEAs to request or receive additional information from their LEC, reducing potential security risks.
FAQs Available: DHCS provided a set of FAQs to address common questions related to this matter.
In conclusion, PPL 23-004R signifies a positive shift in ensuring healthcare information accessibility for everyone, regardless of their abilities, while also acknowledging the unique context in which schools operate. This update streamlines LEAs' obligations and provides clarity and relief to the educational community.
