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    Behavioral Health Rehabilitation Services (BHRS) Frequently Asked Questions

    Below is a list of frequently asked questions and corresponding answers regarding Behavioral Health Rehabilitation Services. In general, answers apply to both the fee-for-service and managed care delivery systems, unless specifically noted otherwise. You can view Medical Assistance Bulletin 01-01-05, which is referenced several times in these questions and answers.

    ASSESSMENT AND ASSISTANCE

    1. Newly hired with six months or more full-time TSS experience -- MA Bulletin 01-01-05 does not say full-time; however, overhead did?

    Response: MA Bulletin 01-01-07, "Addition of Behavioral Health Rehabilitation Services to the Medical Assistance (MA) Program Fee Schedule" specifies that the six months experience must be the equivalent of six months of full-time experience.

    2. If a TSS worker with more than six months experience who already had three hours of Assessment and Assistance is newly hired by another agency, does the worker have to have another three hours of Assessment and Assistance?

    Response: Yes, the three hours of Assessment and Assistance are required any time that a TSS worker is newly employed by an agency.

    3. Can the supervisor bill for Assessment and Assistance for a TSS worker hired before July 1st (hired in June 2001 with less than six months experience)? TSS worker has yet to be an active participant with any clients in the community.

    Response: No, MA Bulletin 01-01-05, "Revisions to Policies and Procedures Relating to Mobile Therapy, Behavior Specialist Consultant, and Therapeutic Staff Support" states that Assessment and Assistance is required only for TSS staff hired on and after July 1, 2001. Therefore, this service may be billed only for TSS workers hired on and after July 1, 2001.

    4. Does Assessment and Assistance require prior authorization?

    Response: In the fee-for-service delivery system, Assessment and Assistance does not have to be prior authorized. In the behavioral health managed care delivery system, providers must follow the procedures established by the BH-MCO.

    5. While providing Assessment and Assistance, does an encounter form get completed? Who signs this form?

    Response: An encounter form does not need to be completed.


    BILLING

    6. Is there a reimbursement rate for this supervision outside the home?

    Response: The Assessment and Assistance fee is billable in whatever setting the service is provided, as long as the setting is one in which the treatment plan specifies that the child should be receiving services. Ongoing supervision is included in the TSS rate, whether provided in the office or on-site, and time spent in ongoing supervision is not billable.

    7. Is the $10 Assessment and Assistance fee added to the regular fee for BS or MT doing supervision?

    Response: Assessment and Assistance is not an MT or a BSC activity. The person is providing Assessment and Assistance because she/he meets the qualifications of a "qualified supervisor," not because she/he is an MT or a BSC. The qualified supervisor may not provide MT or BSC at the same time she/he is providing Assessment and Assistance. Therefore, only the $10 Assessment and Assistance fee and the TSS services may be billed to Medical Assistance.

    8. When a TSS worker is not able to work alone with a child, must the other person be another staff or could it be a parent? If it is another staff could they bill?

    Response: If a TSS worker is not yet qualified to work alone, the other person must be another staff person and may not be a parent. If the services provided by the TSS worker are billed, another staff person may not bill for the same service. If the other staff person is providing Assessment and Assistance, that staff person may bill for Assessment and Assistance.

    9. We are in a very rural county where we have to drive a minimum of 30 minutes just to go to the client's home, school, etc. With the time constraints, supervisory, training, Assessment and Assistance requirements etc., we are finding it difficult to break even financially. Are wraparound services in a rural setting being considered?

    Response: "MA Bulletin 01-01-05, "Revisions to Policies and Procedures Relating to Mobile Therapy, Behavior Specialist Consultant, and Therapeutic Staff Support," provides as follows (Page 10):

    Reminder: In the fee-for-service delivery system, the procedures described in that bulletin [1153-95-01, "Accessing Outpatient Wraparound Mental Health Services Not Currently Included in the Medical Assistance Program Fee Schedule for Eligible Children 21 Years of Age" (Sept. 8, 1995)] may also be used to request an adjustment to the MA fee schedule rate for the three services on the Fee Schedule, when the services are unavailable at the fee schedule rate. Although the fee schedule rate includes administrative expenses such as travel, one of the reasons that may justify an adjustment to the fee schedule rate is that a service is unavailable, particularly in rural areas, because the time spent in travel exceeds the time spent delivering services. In HealthChoices, similar requests may be submitted to the BH-MCO through the procedures established by each BH-MCO.


    CHANGE TO NEW PROVIDER

    10. When a family moves, what steps are necessary to transfer already authorized services to a new provider?

    Response: In the fee for service delivery system, the following process must be followed for transfer of services to a new provider:

    The provider transferring the authorization must write a letter to the new provider documenting the date that the new provider accepted responsibility for providing services. A copy should remain in the provider's file and a copy should be submitted to the Office of Medical Assistance Programs, as specified below.

    Outpatient
    PA/1150 Waiver Services
    P.O. Box 8188
    Harrisburg, PA 17105-8188


    The provider accepting the servicers must submit an unsigned but otherwise completed, MA-97 form listing the start date of services rendered by the accepting provider. Additionally, a cover letter, signed by the clinically responsible person at the accepting agency must be submitted, and must contain the following info.

    1. Contact person at the accepting agency;
    2. Current Prior Authorization Number on the service authorization from the transferring provider to the accepting provider;
    3. The start date of the services by the accepting provider;
    4. A copy of the letter from the transferring provider to the accepting provider (as set forth above).


    DEFINITIONS - PART-TIME/FULL-TIME

    11. What is the definition of hours of a part-time TSS worker?

    Response: Agencies should have a definition of full-time and part-time employment in their policies and procedures. If an agency considers a worker to be full-time or part-time for purposes of benefits and employment status, then generally DPW will also consider that worker to be a full-time or part-time employee.

    Note that, for purposes of the ongoing supervision, all TSS workers must receive MA Bulletin 01-05-05, "Revisions to Policies and Procedures Relating to Mobile Therapy, Behavior Specialist Consultant, and Therapeutic Staff Support." The bulletin does not refer to "full-time" or "part-time" status. Instead, it requires that TSS workers employed 20 hours per week or more must receive at least one hour of supervision per week, and TSS workers employed less than 20 hours per week must receive at least 30 minutes of supervision per week.


    ISPT MEETING

    12. If no ISPT meeting is held, but the ISPT Sign-In /Concurrence Form must be sent in with reauthorization, are signatures required?

    Response: If ISPT input is required, documentation of the ISPT input must be included on the ISPT Sign-In/Concurrence Form and submitted with the reauthorization packet. Actual signatures of ISPT members are required on an ISPT Sign-In/Concurrence Form only when an ISPT meeting is required.


    PROCESS

    13. Under some circumstances during the summer, a child may participate in a week long day camp for 30 hours. The child is recommended to receive 15 hours per week. Can a TSS worker provide 30 hours/week during week one for the child's camp?

    Response: No, the provider may not render services other than as specified in the treatment plan and as authorized. However, the provider could submit a request seeking authorization to provide increased hours for that week, if there is a prescription for the increased hours.

    14. Can a TSS worker provide a modified number of hours for the rest of the month up to 60 total hours?

    Response: No, services must be rendered per week as specified in the treatment plan and as authorized. Because TSS is authorized to afford therapeutic intervention in accordance with specific objectives, goals, and activities as developed by the team and set forth in the treatment plan, it is not appropriate to decrease (or increase) hours in one week because services were provided in an amount higher (or lower) than authorized in a previous week.

    15. A parent calls our agency requesting TSS. We do not accept the referral and direct them to the county. Do we still have any responsibility to record that request?

    Response: Per MA Bulletin 01-01-05,"Revisions to Policies and Procedures Relating to Mobile Therapy, Behavior Specialist Consultant, and Therapeutic Staff Support," the entity to which the request was made must maintain a record of the date of the request. It is suggested that the agency forward a copy of the record to the county. If a provider cannot schedule an evaluation promptly, it should not accept the referral for an evaluation, but should refer the family to the county MH/MR office for assistance in finding a provider.

    16. Are we allowed to say "the intake worker is not here" and not keep a record of the phone call or referral for the purpose of tracking the sixty days?

    Response: No, the entity to which the request was made must maintain a record of the date of the request regardless of whether or not it accepts the referral. If an intake worker is not available, the caller should be told when to call back (or when an agency representative will return the call). The agency must record the date, time and purpose of the call.

    17. Can a child receive TSS/MT/BSC if he/she is involved in a partial hospitalization program given that the TSS/MT/BSC hours are delivered outside of the partial hospitalization program? Example: ("Johnny" attends PHP 8 a.m.-3 p.m. Can he receive TSS/MT/BSC after 3 p.m?)

    Response: In most cases, the needs of a child who participates in a partial hospitalization program should be met through the partial hospitalization program. In extraordinary circumstances, the prescriber may determine, based on the individual needs of the child or adolescent, that TSS, MT and/or BSC services are appropriate. In such cases, in the fee-for-service system, TSS services must be prior authorized, and MT and/or BSC services must be approved through DPW's Program Exception (PE) Process. In the behavioral health managed care delivery system, the request should be submitted through the authorization procedure established by the BH-MCO. If the request is approved as medically necessary, the services may be delivered during the time periods as authorized.

    18. If a child is receiving Partial Hospitalization and TSS is prescribed, but MT and BSC are not prescribed, who writes the treatment plan and supervises the TSS worker?

    Response: TSS services must be incorporated into the child's overall treatment plan. There should be collaboration among all service providers for all services being rendered. The agency that employs the TSS worker is responsible for supervising the TSS worker.

    19. Is the CASSP Coordinator signature required on the Plan of Care Summary if an ISPT meeting is not required?

    Response: The Plan of Care Summary is required to be submitted with the authorization or reauthorization packet regardless of whether the ISPT meeting is required or not. The provider is not required to obtain the signature of the CASSP Coordinator or other county mental health representative on the Plan of Care Summary. Per MA Bulletin 01-94-01, "Outpatient Psychiatric Services for Children Under 21 Years of Age," the provider should continue to send a copy of the Plan of Care Summary to the county mental health/mental retardation representative, to facilitate the coordination among various child serving agencies, even when ISPT meetings or input are not required.

    20. After a prior authorization has been sent in and during that 21-day waiting period, the child has been hospitalized for two to three weeks. Do we use the evaluation that was sent in, or send in the hospital evaluation for new prior authorization?

    Response: If an evaluation was conducted after the Prior Authorization request was submitted, the provider should submit a copy of the evaluation, along with the child's name and 10-digit MAID number via fax to the attention of the Mental Health Services Section at (717) 705-8179. This submission will not be considered a new Prior Authorization request, but will be considered an amendment to the previous Prior Authorization request, and the 21-day Prior Authorization review period will not be extended.

    21. Can the ISPT meeting and Psychological evaluation take place at the same time?

    A: Part of an evaluation includes the gathering of information from individuals involved with the child, which may take place at the ISPT meeting. In addition, a separate individual face-to-face psychiatric/psychological evaluation with the child must occur.

    22. Do all services recommended at the ISPT meeting need to start at the same time?

    Response: No, the services should start as specified in the prescription (not as recommended by the ISPT), which may include separate start dates for some or all services.

    23. Under the 60-day standard, if a family does not show for an appointment, what should occur?

    Response: Any delay attributed to a "no show" or cancellation should be documented in the individual's record. The provider should reschedule the appointment as soon as possible.

    24. What is the county role with finding providers?

    Response: The role of the county is to assist the family in accessing services for children or adolescents who are enrolled in the county MH/MR program.

    25. Can the provider refuse to perform an evaluation if services are not available?

    Response: An evaluation may not be delayed because the provider is unable to staff the case. In this case, the provider, with the family's approval, should perform the evaluation and then contact the county MH/MR program or BH-MCO for referral to another provider.

    26. Can a child have TSS or Mobile Therapy if they do not have MA, but an agency will pay for it?

    Response: Yes, there is no prohibition against a provider rendering services to children or adolescents who are not enrolled in the MA Program. DPW will not pay for services rendered to a child or adolescent who is not an MA recipient.

    27. Once a request for prior authorization has been approved, may the start of TSS services extend beyond 60 days from the date of the evaluation (since the evaluation must have been conducted within 60 days of the expected service start date)?

    Response: The Department expects that evaluations will be conducted promptly so that services will be delivered within 60 days of the date services are first requested. The evaluation must be conducted no later than 60 days before the expected service start date. An unintended delay in service initiation beyond 60 days will not invalidate the authorization, as long as services begin within the authorization service period.

    28. Once a request for prior authorization has been approved, when should service be initiated?

    Response: Each authorized BHR service is expected to begin no later than 60 days after the initial request for services, unless the evaluation prescribes different time frames. Even if not provided, services will be considered to be initiated as authorized within 60 days of the initial request if services are documented to have been offered as authorized within the 60 days and: 1) the parent or recipient delays initiation of service; or 2) the amount of service offered is less than authorized and the family agrees that the amount offered is appropriate.

    29. Can the number of hours (vs. units) be indicated on the Prior Authorization Notice forms issued to providers by Medical Assistance (MA)? Now that a specific formula is used by MA to calculate the exact number of units that will be authorized, it's hard for providers to tell exactly how many hours the number of units authorized equates to, since providers are provided with the exact formula now used by MA (i.e., providers are still using the 4.3 formula, therefore, arriving at requesting a different number of units than what MA is authorizing).

    Response: The notices issued to providers must specify the authorized number of units per month because the PROMISe™ system is programmed to calculate payment based on number of units, not number of hours. To determine the number of hours authorized per week:

    1. Take the units authorized per month and divide by the number of service days in the month = units per service day.
    2. Divide the units authorized per service day by two = hours authorized per service day.
    3. Multiply hours authorized per service day times the number of service days in the reporting week = number hours authorized in the reporting week.


    REPORTING

    30. Are services ever prescribed in ½ hour increments or authorized in ½ hour increments?

    Response: Yes.

    31. Do we still need to turn in MA Encounter Forms?

    Response: No. DPW uses the MA Encounter Form as a mechanism to assist providers who bill via continuous print forms (pinfed), diskette, modem or the tape-to-tape billing mode. The Encounter Form is used as a means to obtain the recipient's signature, certifying that:

    1. The recipient received the service indicated on the invoice; and
    2. The recipient identified on the Pennsylvania ACCESS card is the recipient who received the service.

    The Encounter Form is to be retained by the provider. Please refer to the provider handbook, Section V - Billing Information, A., 5.

    32. For a prescription for 20 hours per week, may the provider deliver eight hours one day and four hours the rest of the days?

    Response: Services should be delivered as specified in the treatment plan, consistent with the prescription set forth in the evaluation.

    33. What if there is a discrepancy between provider agency and family regarding the date that services were first requested?

    Response: Per MA Bulletin 01-01-05, "Revisions to Policies and Procedures Relating to Mobile Therapy, Behavioral Specialist Consultant and Therapeutic Staff Support," the entity to which the request was made should maintain a record of the date of the request. If BHR services are prescribed, members of the ISPT should confer with the parent/guardian/recipient at the first ISPT meeting to confirm the date that the parent/guardian/recipient (if 14 years or older), or other person acting with the family's concurrence, first requested behavioral health services and then record the date on the ISPT Sign-In/Concurrence Form. This date should be supported with accurate documentation by the entity receiving the request. If there is a disagreement of the identified date between the provider and the parent, the date identified by the parent should be recorded on the ISPT Sign-In/Concurrence Form. The provider should prepare a written statement explaining the disagreement and submit the statement and supporting documentation along with ISPT Sign-In/Concurrence Form with the Prior Authorization request.


    SERVICE SYSTEMS

    34. If a child has a mental retardation diagnosis and is not receiving MR services, but is receiving BHR Services and is in education, is he a three-system kid?

    Response: Generally, a child who has a mental retardation diagnosis but is not receiving services from the MR system is a two-system child. However, if the child is awaiting MR services or the county MR program is otherwise involved with the family, then the child is a three-system child.

    35. Is Mental Health a separate service system when counting the number of systems involved with a family?

    Response: Mental health is counted as one system when determining the number of systems in which the child is involved.

    36. If the child does not receive service (TSS, MT or BSC) in school and he/she is doing well, is it mandatory that education be involved?

    Response: No, it is not mandatory that education be involved. However, with approval from the parent, a representative from the educational system should be invited to participate in the ISPT meeting regardless of how well the child is doing in school.

    37. If a child is in the educational system and does not require services within the school system, is school considered "a system" when determining how many systems are involved with child?

    Response: Yes, education is considered a system whether or not the child has need of services in the school.

    38. Is education regarded as a system if it is not special education?

    Response: Yes.

    39. Does it matter how many services a child receives within a system, as it relates to the scheduling of an ISPT meeting?

    Response: No, it does not matter. For example, even if a child or adolescent is receiving several mental health services, mental health is considered only one system.


    SUPERVISOR QUALIFICATIONS

    40. Qualified Supervisor -- "employed by..." -- can that be by contract or must it be a full-time employee?

    Response: It can be either, as long as the qualifications for a supervisor are met.

    41. What is a mental health degree that is sufficient for the supervision of TSS workers? Please define.

    Response: The intent of the educational requirement is to ensure that individuals have substantial course work related to the provision of mental health services. Providers are responsible for ensuring that the individual's qualifications meet this requirement.

    42. MMR providers have been able to use master's level Qualified Mental Retardation Professionals (QMRP) as supervisors and Behavioral Specialist Consultants. Each child's service Q: description included proof of the QMRP requirements by the staff. These followed the instructions issued by the Department. Our packets were sent every four months for all services to the regional OMR office and then forwarded to OMA. Our question is: Would master's level Special Education professionals be disqualified by the MH qualification? This would leave out the people best qualified for MR kids.

    Response: Providers that are delivering services in accordance with previously approved service descriptions, which identify different staffing qualifications for supervisors and BSCs, may continue to provide those services. In accordance with MA Bulletin 50-99-03, "Procedures for Licensed, Enrolled Mental Retardation Providers to Access and Submit Claims for Outpatient Behavioral Heath Services for Individuals Under 21 Years of Age," effective Dec. 3, 1999, (at p. 3), providers who intend to deliver or supervise services with staff who do not meet the staffing qualification requirements listed in MA Bulletin 01-94-01, "Outpatient Psychiatric Services for Children Under 21 Years of Age," effective Jan. 1, 1994," or MA Bulletin 01-05-01, "Revisions to Policies and Procedures Relating to Mobile Therapy, Behavior Specialist Consultant, and Therapeutic Staff Support," must submit an authorization request, and accompanying service description, through the program exception process as specified in MA Bulletin 1153-95-01, "Accessing Outpatient Wraparound Mental Health Services Not Currently Included in the Medical Assistance Program Fee Schedule for Eligible Children 21 Years of Age", effective Sept. 8, 1995. Unless authorized through this process, a person holding a master's degree in special education would qualify only if he or she had substantial coursework related to the provision of mental health services.

    43. What are educational/job requirements for a TSS worker supervisor?

    Response: In order to be qualified to conduct either the initial Assessment and Assistance or the ongoing supervision of TSS workers, the supervisor must be: 1) a licensed mental health professional; or 2) a person with a graduate mental health degree and at least one year of experience either: a) in a CASSP service system (employed by or under contract to children and youth services, juvenile justice, mental health, special education, or drug and alcohol, working with children); or b) employed by a licensed mental health services agency or subcontracted agency.


    TSS SUPERVISION

    44. Must TSS workers have only one overall supervisor who will oversee the TSS worker's cases?

    Response: For consistency, the agency that employs the TSS worker should ensure that it employs and assigns one supervisor who provides the required ongoing supervision of the TSS worker. The BSC or MT for a particular child is not the supervisor of the TSS worker(s) for the child. The BSC or MT will provide clinical consultation as appropriate, but does not become the TSS supervisor by doing so. BSCs or MTs may be TSS supervisors because they independently meet the qualifications for a supervisor, not because they provide BSC or MT services to the child.

    45. What do we do when one TSS worker has two cases under two different BSC/MT? Who supervises?

    Response: The BSC or MT for a particular child is not the supervisor of the TSS worker(s) for the child. The BSC or MT may provide clinical consultation as appropriate, but does not become the TSS supervisor by doing so. BSCs or MTs may be TSS supervisors because they independently meet the qualifications for a supervisor, not because they also provide BSC or MT services to the child. The agency is responsible for assigning a supervisor to provide ongoing supervision to the TSS.

    46. In the event that a TSS worker receives supervision during a regularly scheduled time once a week for one hour with a primary supervisor in the context of a group, can a MT or BSC provide the on-site supervision component?

    Response: The MT or BSC could perform the on-site supervision because he or she meets the qualifications for a supervisor, not because he or she is the MT or BSC assigned to the case. This supervision is distinct from the clinical consultation that a MT or BSC provides. Clinical consultation does not meet the requirement for on-going supervision. If someone other than the designated supervisor provides the on-site supervision, there must be feedback from this person to the designated supervisor.

    47. In regard to the ongoing supervision requirements for TSS workers, does the supervision need to be face-to-face or can it be performed over the phone?

    Response: Ongoing supervision may occasionally be performed over the telephone; however, face-to-face, on-site supervision must also take place.

    48. Can supervisors supervise Mobile Therapists and TSS workers as long as they stay within nine full-time?

    Response: The supervisor may supervise nine full-time equivalent TSS workers. The supervision of MTs, by the same supervisor, must fall within that supervisor's scope of practice.

    49. Can group supervision qualify for requirements? Example: one supervisor and three TSSs in room - session, one hour. Does that count for their hours/week of supervision?

    Response: Yes; however, there must be periodic one-to-one supervision, in addition to group supervision.

    50. What if the supervisor is ill or on vacation for a week?

    Response: The provider is responsible to ensure that another qualified supervisor is available and supervision takes place as required.

    51. Can a TSS worker working less than 20 hours per week receive two hours supervision per month instead of ½ per week?

    Response: No, the required supervision must take place each week.

    52. Can a supervisor supervise the TSS worker outside of the home and without presence of the family?

    Response: Yes, it is expected that supervision will take place in the office, as well as in the community.

    53. Can a TSS worker bill TSS hours when receiving on-site supervision?

    Response: Yes, when the TSS is providing services while supervision is being performed.

    54. I am a psychologist. What are the maximum hours I can be reimbursed for TSS?

    Response: MA Bulletin 01-01-05, "Revisions to Policies and Procedures Relating to Mobile Therapy, Behavioral Specialist Consultant and Therapeutic Staff Support Services," states that "Each supervisor may provide supervision to no more than nine (9) full-time equivalent TSS workers."

    55. A TSS worker is working with a client who has specialized needs and interventions. A "specialized supervisor" will work with the TSS worker on that case, as not all supervisors can be expected to know all specialty workers. Is this okay?

    Response: This would be considered clinical consultation provided by the MT or BSC who specialized in providing the service. The BSC or MT for a particular child is not the supervisor of the TSS worker(s) for the child. The BSC or MT will provide clinical consultation as appropriate, but does not become the TSS supervisor by doing so. BSCs or MTs may be TSS supervisors because they independently meet the qualifications for a supervisor, not because they provide BSC or MT services to the child.

    56. Do children receiving services from a BHRS provider need to have a Base Service Unit case manager?

    Response: Neither DPW nor a provider may require that a child have a BSU case manager in order to be eligible for MT, BSC, or TSS services. Even when the family is not enrolled in the BSU or does not have a BSU case manager, the county must be invited to and participate in the ISPT meeting, either in person or through the mechanism approved by OMHSAS for alternative participation.

    57. Please define what consultative supervision is and what it includes?

    Response: Consultative supervision is the supervision initiated by the TSS worker on an as needed basis. If consultative supervision is utilized to meet the ongoing supervision requirement, then the provider must ensure that documentation of supervision takes place as required.


    SUPERVISION/RECORD KEEPING

    58. Would on-site supervision be documented slightly differently?

    Response: The enrolled provider must maintain a written record of both the Assessment and Assistance and the ongoing supervision sessions that includes the following information:

    • The date and time of the session;
    • The location of the session;
    • The exact clock hours spent in the session;
    • A narrative descriptive summary of the points discussed during the session; and
    • The dated signatures of both the supervisor and the supervised TSS worker.

    59. If you are in group supervision and you are not discussing your client that week, how do you document that, and what would you put for projected action steps?

    Response: It is not a requirement that providers document that each client is discussed at each supervisory session. (See response to Question 56 for supervision/record keeping requirements.)

    60. Where does the provider store record of supervision?

    Response: The provider should document the supervision in the employee's record and NOT in the client's record.


    TSS WORKER QUALIFICATION

    61. Is a resume sufficient to document the one year CASSP experience for Qualified Supervisor Non-Human Services BA/BS?

    Response: The provider must verify the employee's work history as listed on her/his resume. In addition, the provider must document that it verified the information listed on the employee's resume.

    62. Define "Day Care" - Does it include these scenarios: Babysitting, part time for 10 + years = three years day care; being a parent for 3+ years; or an LPN (or 60 + credit student) who has worked as babysitter for several years or who has raised own children?

    Response: None of these examples meet the definition for "Day Care." Day Care experience is employment by a licensed, certified, or registered provider of day care services.

    63. Does Occupational Therapy (OT) and Speech Therapy (ST) qualify as a "Human Service" field to allow Bachelor's without one year paid experience to do TSS?

    Response: Yes.

    64. The staffing qualifications set forth in MA Bulletin 01-01-05, "Revisions to Policies and Procedures Relating to Mobile Therapy, Behavioral Specialist Consultant and Therapeutic Staff Support Services," are the minimum required to participate in the MA program and are not intended to replace or supplant staffing or other requirements that are imposed on providers under other provisions of state law. Interpretation of the Psychology Board Regulations should be referred to the Pennsylvania State Board of Psychology.

    Response: Yes.

    65. If a person has one-year experience in CASSP system, but not as TSS worker, do they require training as a new TSS worker?

    Response: Yes.

    66. Is there a specific method of documentation that is needed to document supervisor/TSS worker ratio to show nine full-time staff or less?

    Response: No, the provider has the flexibility to determine the method for documentation of the Supervisor/TSS worker ratio.


    TSS WORKER TRAINING

    67. Is there any reimbursement for training time for TSS workers?

    Response: No.

    68. Do all the training sessions listed in the Bulletin need to be addressed? Example: CPR could take up to eight hours of training. Do they only need seven more hours before working alone?

    Response: All of the training topics listed in MA Bulletin 01-01-05, "Revisions to Policies and Procedures Relating to Mobile Therapy, Behavioral Specialist Consultant and Therapeutic Staff Support Services," are to be covered as part of the training hours required for new TSS workers (15 prior to working alone and 24 within the first six months of working with children). The 20 hours of training required for TSS workers after their first year of employment as a TSS is intended to provide them with additional knowledge of and skills in delivering TSS services. The agencies have the discretion to determine which topics identified in the Bulletin should be covered in the ongoing training or to include other topics.

    69. What consists of appropriate training documentation that a TSS worker can carry from one agency to the next?

    Response: MA Bulletin 01-01-05, "Revisions to Policies and Procedures Relating to Mobile Therapy, Behavioral Specialist Consultant and Therapeutic Staff Support Services," sets forth the responsibility of the provider to maintain documentation that TSS workers have received the required training. If a TSS worker leaves the employment of that provider or agency, a copy of the record should be provided to the employee.

    70. Can Spanish language instruction be included in TSS worker training hourly requirements?

    Response: No.

    71. If an agency provides more than 15 hours prior to allowing a TSS worker to work alone with children, do those hours count towards 39?

    Response: Yes.

    72. Can training be done in-house?

    Response: Yes.

    73. If a person is hired on Aug. 1, 2001, received 15 hours of initial training. (Three months passes prior to assignment to a child). Assigned to a case on Nov. 1, 2001. Do we have six months from Nov. 1, 2001 to complete the 24 hours of additional training?

    Response: Yes.

    74. In the Discrete Trial Intervention (DTI) Autism program, I have new workers who, as part of their training, go out on-site to observe experienced workers. This is specifically to learn DTI for autistic children and is specific to each child. Could this count for training?

    Response: Yes, this could count for a portion of the training; however, all topics listed in MA Bulletin 01-01-05, "Revisions to Policies and Procedures Relating to Mobile Therapy, Behavioral Specialist Consultant and Therapeutic Staff Support Services" must be addressed during the initial training required before the TSS worker may work alone with children.

    75. Is it acceptable that our experienced workers are billing while the new workers observe?

    Response: Yes, the experienced worker may bill provided that he/she is providing authorized TSS services. However, the new TSS worker may not bill for time spent observing.

    76. Each child has separate Discrete Trial Intervention (DTI) drills. Could this count as separate training even for experienced workers?

    Response: Yes, provided the parent(s) gives permission for additional staff to observe interventions with the child.

    77. Is "required reading" and written assessment of reading by TSS worker acceptable for training?

    Response: No, required reading and written assessment of reading is not considered training.