TO:CFC Program Managers, Service Coordinators and EI Providers
FROM:Janet D. Gully, Chief
Bureau of Early Intervention
DATE:January 11, 2008
SUBJECT:Evaluation and Eligibility Determination Questions and Answers
EI Bureau staff has been receiving and responding to many questions and issues in concerns to evaluation and eligibility determination. This document is meant to address many of those questions and issues.
Eligibility Determination:
Per Part C of the Individuals With Disabilities Education Act it is required that a “comprehensive, multidisciplinary evaluation” occur. Multidisciplinary is defined under 34 CFR Sec. 303.17 of the regulations under Part C as “the involvement of two or more disciplines or professions in the provision of integrated and coordinated services, including evaluation and assessment activities in Sec. 303.322 and development of the IFSP in Sec. 303.342”.
In Illinois nursing, nutrition or counseling assessments do not determine eligibility for Early Intervention. These are services that may require further assessment to determine need once a child has been determined eligible.
Question: A child in intake has two evaluations to determine eligibility, a global evaluation and a PT evaluation. The global evaluation found the child eligible based upon a delay greater than 30% in gross motor. The PT evaluation did not find the child eligible. Would this child be considered eligible?
Answer: No. A global evaluation is a general testing of the five domains and is not domain specific. Because the evaluator that found the child ineligible was trained to administer an in-depth domain specific evaluation, and that evaluation found the child ineligible, than the child would be deemed ineligible for services. The result’s of a domain specific evaluation should always supersede the results of a general global evaluation.
Question: If a global evaluation finds a 30% or more delay in multiple domains, is the CFC required to complete discipline specific evaluations in each of those domains prior to writing the initial IFSP?
Answer: Yes. The global evaluation would provide information in each of the five domains. For each domain that a 30% or more delay is found, further assessment in each of those domains needs to occur prior to the IFSP meeting so that a comprehensive, multidisciplinary IFSP can be written. The exception is if a Developmental Therapist completes the global. In this case further assessment would not have to occur in the cognitive domain. NOTE: Please keep in mind that in Illinois a global evaluation can only be completed by a provider that is credentialed/enrolled as a Developmental Therapist, Nurse or Counselor Evaluator. See the document entitled “Early Intervention Service Descriptions, Billing Codes and Rates” for more information.
Question: When is it appropriate for a provider to base eligibility determination on clinical judgment?
Answer: If a child is unable to be appropriately and accurately tested by the standardized measures available, the provider may determine eligibility based upon informed clinical judgment (see 89 IL Admin Code 500, Sec. 500.20, definition of eligible children or eligible child). Activities used to determine clinical judgment shall include observation and parent report and shall be described in the written evaluation report produced by the provider.
Question: For initial eligibility, if there are only two evaluators (for example a ST and DT evaluator) and the ST finds eligibility, however the DT doesn't, how would eligibility be determined if the DT can't state that in her clinical judgment the child exhibits at least a 30% delay and can't qualitatively review the eligible report? How does consensus of the team make the child eligible for initial eligibility?
Answer: The DT can review the eligible report and based upon consensus of the multidisciplinary team clinical judgment can be determined. This is not clinical judgment of one person who cannot complete testing as identified in the previous question. This is clinical judgment by consensus of the multidisciplinary team based upon a discipline specific indepth evaluation. This activity would occur prior to the IFSP meeting. Clinical judgment would be documented in service coordination case notes and on the eligibility letter sent to the family.
Question: If an IFSP has been written and is in place, and later it is determined that an evaluation to determine the need to add a new service must occur, should the service coordinator give the evaluator who is going to complete the new evaluation a copy of the existing IFSP?
Answer: Yes. The service coordinator should give the evaluator a copy of the existing IFSP and copies of the most current evaluations. In addition, if pertinent to the case the service coordinator should also get a signed consent to release any medical records that were obtained from entities outside of the EI system.
Question: Are original copies of evaluation/assessment reports required for the CFC file?
Answer: Originals are preferred, but a copy will be considered acceptable if the CFC is unable to obtain the original. If the CFC is unable to obtain the original, the service coordinator should make sure that the copy is complete.
Question: Are all providers required to submit evaluation/assessment reports in the EI report format?
Answer: Yes. Service coordinators should not accept reports that are not written in the EI report format. Entities that receive payment for EI services have signed the EI “Agreement for Authorization to Provide Early Intervention Services”. By signing that document all payees agreed that they or their staff would “provide a report of findings in a format designated by DHS that describes the tests/methods used in evaluation/assessment activities”. The required report format can be found in the provider handbook entitled “Early Intervention Service Descriptions, Billing Codes and Rates”.
Question: When are provider’s required to submit their evaluation/assessment reports to service coordinators?
Answer: Providers are required to submit evaluation/assessment reports within 14 calendar days of the receipt of an authorization, or a request to complete an assessment if an authorization was generated at the begin date of the IFSP. In extenuating circumstances, if the report cannot be completed in 14 calendar days, the CFC Manager may determine if a 5-day extension is necessary. If the manager approves an extension, the service coordinator will adjust the authorization to reflect the extension.
Question: Are providers who complete evaluations/assessments required to attend the IFSP meeting in person?
Answer: Providers should attend the IFSP meeting in person. However, if the provider cannot attend in person, the service coordinator can make arrangements for the provider to participate in the meeting by telephone conference call. Providers must accept responsibility for phone charges for IFSP meeting conference calls if done for their convenience.
Question: Do providers have to attend the full IFSP meeting in order to receive authorization for payment?
Answer: Yes. Whether the provider attends the IFSP meeting in person or via a conference call, the provider is required to attend the entire meeting in order to receive authorization for payment. Part C of the Individuals With Disabilities Education Act requires the development of a comprehensive, multidisciplinary IFSP. In order for this to occur, the multidisciplinary team must come together to write the IFSP. Providers who call in and simply state the results of their evaluations/assessments and hang up are not participating as a member of a multidisciplinary team. But as an individual who just wants to complete their part and move on.
Question: Can an evaluation by audiologist that has been completed to determine the range, nature and degree of hearing loss and communication functions also be used to determine eligibility for Aural Rehabilitation Services?
Answer: No. An aural rehabilitation assessment must be completed using the aural rehab assessment code identified in the “Early Intervention Service Descriptions, Billing Codes and Rates” document.
January 2008