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Teletherapy and Compliance

FERPA and HIPAA Requirements  
  • Beware of free online platforms and the information collected by that platform.  Make sure the platform being used for teletherapy is HIPAA and FERPA approved.  Many free online platforms collect information and therefore are not considered compliant.  
  • The therapy session needs to be available only to those participating.  Observation by a parent or sibling would not violate FERPA.  Be careful that services are indeed secure and private.
  • In a group setting, it is important to limit the amount of information given on the screen.  Perhaps use only first names, avoid references to individual IEPs during a group meeting, and use an approved platform.
  • It is the responsibility of the provider to check for additional consent notices that need guardian approval specific to teletherapy.  Check the DPHHS website under service provider type to determine if you need additional authorization for telehealth services. 

School Based Services Manual
The DPHHS Manual was just updated
Telehealth services are allowed for Physical Therapy, Occupational Therapy and Speech Therapy. All Montana Medicaid covered services delivered via telemedicine/telehealth are reimbursable so long as such services are medically necessary and clinically appropriate for delivery via telemedicine/telehealth. 
Covered therapy services include the following:
Restorative therapy services when the particular services are reasonable and necessary to the treatment of the member's condition and subsequent improvement of function. The amount and frequency of services provided must be indicated on the member's IEP. Assessment services to determine member medical needs and/or to establish an IEP, as long as the assessment results in health-related services documented in the IEP. 
Service Requirements For all therapies being billed, they must be included in the student's IEP.
Services Restricted Montana Healthcare Programs does not cover therapy services that are intended to maintain a member's current condition but only covers services to improve member functions.
You can find the School-Based Services manual here

Thank you for filling out the Survey in March!

We received over 140 responses to the Medicaid survey sent out in March.  Thank you for the kind words and fantastic suggestions.  We will immediately adopt the suggestion to email a confirmation when documents are sent via ShareFile.  Thank you for this suggestion and many others.  Our office will be reaching out soon to those that asked to be contacted with comments and ideas.  

If you need a little refresher on logging services, check out the Service Portal Manuals.

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