Frequently Asked Questions

When using electronic signatures, be sure to follow any guidance issued by your district and the Pennsylvania Department of Education (PDE) (https://www.education.pa.gov/K-12/Special%20Education/FAQContact/Pages/AddInfoCOVID19.aspx) as well as information provided in Section 5.3 of the SBAP Handbook.

Yes. Transportation is an individual service regardless of other students being on the bus or van.

Pennsylvania MA Regulations (55 Pa. Code § 1101.51 (e)) require medical and fiscal records that fully disclose the nature and extent of the services rendered to MA beneficiaries be retained for at least four years, or longer if required by the Health Insurance Portability and Accountability Act of 1996, Pub. L. No. 104-191 and implementing regulations at 45 CFR Parts 160, 162, and 164. Records must be retained even if:

• the student “ages out” of the program;
• the student moves out of the school district; or
• the local education agency (LEA) ends its participation in SBAP.

Additional information related to documentation requirements is included in Chapter 5 of the SBAP Handbook.

LEAs may contact The System for Award Management (SAM) directly via the Federal Service Desk at https://www.fsd.gov/gsafsd_sp or at 866-606-8220.

MA Bulletin 99-11-05 establishes the requirement of monthly preclusion/exclusion checks for all providers. Additionally, section 5.4 of the SBAP Handbook establishes the requirement of monthly Preclusion/Exclusion checks within the SBAP. Providers who participate in the MA Program are required to screen their employees and contractors, both individuals and entities, prior to hire and monthly thereafter, to determine if they have been excluded from participation in Medicare, Medicaid, or any other federal health care program.

Yes. While provider logs are required to contain exact “Start Time” and “End Time”, non-consecutive service minutes may accumulate on a single date of service for the same service type provided to the same student. For example, the PCA assists the student with toileting from 10:02 – 10:10 and then opens food containers and assists with feeding from 11:25 – 11:35. Those minutes may accumulate. Reminder: rounding up service minutes is prohibited. Please see Section 4.4 of the SBAP Handbook for more information related to Provider Logs.

Supervisory signatures are required on logs for services provided by the following providers:

• Personal Care Assistant
• Occupational Therapy Assistant
• Physical Therapy Assistant
• Audiologist Assistant
• PDE-Certified Speech Language Pathologist (CSPG 63)
• Clinical Fellow in Speech Language Pathology (includes provisional licensee)
• Speech Assistant

Supervisory signatures are required for both paper and electronic logs.

Check with the agency that granted the certification to determine if any extensions were granted. If there was an extension, you will need to maintain documentation of that extension along with the PCA’s original certification. Providers should be sure to allow enough time to renew the credential before the extension expires.

Written documentation from the graduating institution may be substituted for the diploma, such as an official letter or email sent by the district providing the individual’s name and graduation status. Also, verification of a higher level of education, such as an associate degree or bachelor’s degree, is acceptable documentation, as the individual would have had to meet the requirement of high school graduation to be admitted to a higher-level educational program. Personal attestation, as may be provided on an employment application, is not sufficient documentation.

The description of "needs more information" is often associated to Third Party Liability, which requires no action on the part of the LEAs. PCG will continue to work with DHS to provide more details on denial descriptions as appropriate.

A provider can be inactivated after all associated information, such as provider certification and service logs are entered into EasyTrac. All service logs that have the necessary compliance information, submitted within timely filing limits, will continue to be processed. However, if service logs associated with an inactive provider appear in an exception report, then the provider would need to be reactivated and the certifications entered for processing. Once processed, the provider can then be re-inactivated. The provider should be inactivated only when all compliance information associated with the provider you seek to inactivate has been entered.

Whether staff or contractors should or should not be listed on a Staff Pool is ultimately up to the LEA’s discretion. The decision to add Special Education teachers should be based on the source of funding for the position and the activities they engage in rather than their title. Some items to consider:

• Staff that are 100% federally funded should not be included on the time study as none of their costs are reimbursable.
• Only qualified direct service providers should be on the Direct Service Staff Pool.
• Staff who spend most of their time (on a typical day) supporting the Special Education program and/or health-related services in an IEP and are not a direct service provider could be considered further for the Admin Pool.

Yes, if the speech therapist with a provisional license is providing speech services under supervision and their services are being submitted to Medicaid for reimbursement, the LEA may add the speech therapist to their cost pool. If they are not being supervised and/or not being submitted to Medicaid for reimbursement, they should not be included in the Time Study.

You may report the tuition costs for a student if the health-related service is being delivered by the school to which you are paying tuition AND you have verified that that school is not submitting direct service claims to MA for the student. To receive reimbursement for allowable health-related tuition costs, LEAs must still participate in all program components as indicated in the LEA Agreement and Section 1.3.b. of the SBAP Handbook, including the submission of compensable direct service claims.

If the cost for OT service is OUTSIDE of the tuition you may include the provider in the staff pool list (SPL) for your LEA and submit the services that the OT provides for your students. You MUST include the OT on the SPL and that provider must participate in the Random Moment Time Study in order to then bill for those OT services.

UICRs are calculated and certified by PDE as part of the Annual Financial Report (AFR) submission. The published deadline to complete the AFR is October 31st. DHS has no input or effect on the timetable for processing AFRs or calculating rates; therefore, it is recommended that the AFR be submitted by 10/31. However, all UICRs received by DHS from PDE by February 15th will be utilized for the relevant MAC claim and Cost Settlement Calculations.

In accordance with the approved payment methodology outlined in Pennsylvania’s Medicaid State Plan, DHS annually revises the provider-specific interim rate (rate) for LEAs. DHS must adhere to the process for calculating rates as outlined in the State Plan; therefore, no adjustments are anticipated.

Yes. Effective with the May 2022 SBAP Handbook, an Orientation & Mobility (O&M) Specialist must be certified by either the Academy for Certification of Vision Rehabilitation & Education Professionals (ACVREP) or the National Blindness Professional Certification Board (NBPCB) to bill for services through SBAP. While the requirement for O&M specialists to hold a Pennsylvania Department of Education (PDE) teaching certification for the visually impaired was removed, holding a PDE teaching certification for the visually impaired does not disqualify the provider from billing SBAP.

A BLS Certification is acceptable to acknowledge verification of CPR certification, but the Personal Care Assistant (PCA) would still require a first aid certification, as well as proof of education.

Only a few provider types can sign the MPAF for all SBAP service types. Section 4.2 of the SBAP Handbook outlines which practitioners are able to order or prescribe SBAP services, acting within their scope of practice and enrolled in the Medical Assistance (MA) Program. Please see the attached chart as a helpful reference.

No, because that authorizes one session per month lasting 120 minutes. Writing “individual, 1x/month 120 minutes” is not the same as “individual, up to 120 minutes per month. The IEP and MPAF should reflect what the student is expected to receive, such as “2x/week for 15 to 30 minutes, up to 120 minutes per month”. In its 2022 Compliance training, the Bureau of Program Integrity (BPI) cautions against using the words “up to” unless it is a nursing or PCA service.

In the Commonwealth of Pennsylvania, school psychologists are certified by the Pennsylvania Department of Education (PDE). The national certification on its own does not meet the requirements for MA billing. However, individuals certified by the National Association of School Psychologists will be granted the highest level certification available from PDE as a school psychologist (22 Pa. Code § 49.65(d)). Documentation of this PDE certification should be maintained by the LEA as verification that the provider is eligible to bill for his/her services as a school psychologist as described in Section 3.12 of the SBAP Handbook.

No, the individual must apply for PDE certification. The individual must be issued the PDE certification before billing for services in the SBAP.

No. Section 3.3 of the SBAP Handbook states that a teacher of the hearing-impaired must meet one of the following requirements:

• Has a professional certificate issued by the Council on Education of the Deaf (CED); or
• Has a Master’s degree, from an accredited college or university, with a major in teaching of the hearing-impaired or in a related field with comparable course work and training.

A PDE-certified teacher of the hearing-impaired (CSPG No. 62) must meet the above requirements to be considered a qualified provider for SBAP.

No. Section 3.13 of the SBAP Handbook states that a provider of social work and counseling services must meet one of the following requirements:

• Licensed Social Worker
• Licensed Professional Counselor
• Licensed Marriage and Family Therapist

A PDE-certified school social worker (CSPG No. 201) must also hold one of the licenses listed above to meet the requirements of a qualified provider for SBAP.

No, the DNP is a degree, not a job title, and earning a DNP does not make an individual a physician, nor does it inherently indicate that an individual is working in direct patience care. Please see this helpful chart of authorizing providers and the services they may order/prescribe on the MPAF, which is available on the SBAP Website.

Additionally, Section 4.2 of the SBAP Handbook includes an exhaustive list of all providers currently able to authorize the medical necessity of SBAP services on the MPAF when enrolled in the MA Program. If the individual with a DNP has passed the board examinations to receive their CRNP license, they may enroll as a MA Provider Type 09 – CRNP, which is already an approved provider type for signing the MPAF for all services excluding assistive technology devices, PCAs, and physician services, provided there is a collaborative agreement with a licensed physician in Pennsylvania to order, refer or prescribe services, as described in this section.

Yes. The Commonwealth Secondary School Diploma (CSSD) is a high school equivalency credential available to Pennsylvania residents who do not possess a high school diploma and who have met criteria specified in the Pennsylvania Code (22 Pa. Code § 4.72).

No. This certificate does not meet the equivalency of a high school diploma or general equivalency diploma. Documentation of education requirements as set out in Section 3.8 of the SBAP Handbook must be maintained for an individual to be considered a qualified provider.

The Department of Human Services is not aware of any currently available, fully-online CPR preparation courses that result in valid certifications. Acceptable documentation for a PCA to bill for services in the SBAP is a CPR certification card that includes:

• individual’s name,
• valid begin and end dates,
• name of the organization granting the certification, and
• an authorized signature.

Online courses for CPR certification may not include the opportunity for the individual to demonstrate skill proficiency to a certified instructor; therefore, the course may not meet requirements for workplace safety certification. Blended learning courses require that the individual complete both the online and in-person portions of the course before a valid certification card is issued.

No. Documentation of CPR and First Aid certification must come from the granting agency with valid start and end dates of certification. Additional information about Documentation of Credentials Maintained Onsite can be found within Section 3.8 of the SBAP Handbook.

Please remember that although no services may be billed prior to the date of signature on the Parental Consent, additional requirements must also be in place, including the IEP and authorization of that service or evaluation on the Medical Practitioner Authorization Form (MPAF).

Within the SBAP, an initial evaluation occurs any time that a student is evaluated or assessed in a service type under which they have not been previously evaluated. This can occur both when the initial IEP is being completed (in which case, the Date of Services used for SBAP billing is either the IEP Meeting Date or the child’s 3rd birthday, whichever is later), and when a new service type is being evaluated when an IEP already exists (in which case, the Date of Service used for SBAP billing is the last date the evaluation activities with the student were performed). In both of these cases, the LEA would have the ability to bill for those evaluations, provided the Parental Consent, the IEP, and the MPAF are all signed on or before the date of the IEP Meeting. See Section 4.8.d of the SBAP Handbook for additional information on billing evaluations.

Parental Consent documents are now available on the SBAP Website as linked below:

• PA Parental Consent for Medical Assistance (MA) Billing: English | Spanish
• PA Annual Notice of Parental Consent for MA Billing: English | Spanish

Yes, parents/guardians must consent to their student receiving services via telehealth. Refer to Medical Assistance Bulletin 99-23-08 titled “Updates to Guidelines for the Delivery of Physical Health Services via Telehealth,” and any subsequent guidance issued by DHS on the use of telehealth. Documentation of this consent must be maintained along with other service documentation for the student.

Both the Medical Practitioner Authorization Form for SBAP Initial Evaluation Services and the Medical Practitioner Authorization Form for SBAP Services are now available on the SBAP Website.

It continues to be the LEA’s responsibility to ensure that units billed do not exceed those authorized. There is no automatic alert associated with billed vs. authorized services in MAXCapture; however, LEAs may enter units authorized per service type as an optional field. When this information has been entered, LEAs will have the ability to run reports through MAXCapture which can help LEAs identify areas of over- and under-billing.

LEAs are encouraged to conduct self-audits to ensure services being logged and put through for billing meet all areas of compliance. A Self-Audit Record Review Document has been developed to aid in these self-audits, and is available on the SBAP Website.

LEAs can run reports through MAXCapture which compare units authorized (when information has been data-entered into the MPAF screen) against units billed, which can help LEAs identify areas of over- and under-billing.

Section 3.8 of the SBAP Handbook outlines that for personal care services to be compensable, they must be:

1. In-person with the student (as a 1 to 1 service);
2. A medically necessary service (as established by the IEP and MPAF); and
3. NOT educational in nature.

Some services will be clearer to distinguish between medical and educational than others. When a PCA logs that they cued a student to pay attention to a math assignment, for example, it is important to also note the reason prompting/cuing was needed:

• If the service delivered to the student was to address a medical condition or disability as outlined in the IEP, this would be a billable service.
• If the service was more accurately a PCA prompting the student through a math assignment to address an educational goal in the IEP, this would not be a billable service.

When service logs and accompanying documentation are not clear about which IEP goals are being addressed by Personal Care Services, auditors may not be able to defend that a medically necessary service took place, leading to those claims being recouped.

No. This scenario describes general supervision of multiple students, which is not a billable, medically necessary, one-to-one personal care service. Anytime a PCA is monitoring or working with multiple students, regardless of whether those services were logged for only one student or multiple, that time may not be billed to MA for reimbursement.

Instructional I and Instructional II certifications are PDE certifications. PDE-certified SLPs may bill for services in the SBAP when they meet the supervision requirements as described in Section 3.15 of the SBAP Handbook. The only credentials for providing speech and language services that do not require supervisory signature are a Pennsylvania Department of State (DOS) license or a Certificate of Clinical Competence (CCC) from ASHA.

Additional Frequently Asked Questions around SLP credentialing requirements are included in the Speech Language Pathologist Credentialing & Supervision Requirements Fact Sheet available on the SBAP Website.

The first consideration is that the IEP and MPAF should indicate whether the service authorized is individual or group. Regardless of who else is in the room at the time of actual service delivery (such as students in a classroom or in the cafeteria for lunch), an individual service is when the direct service provider is providing a specific service to that individual student. If generalizing a specific student’s skills into the classroom setting on an individual basis, the other students in the classroom would not be counted or considered a group.

A “group” session occurs when a service is provided to two or more students in the same session. There is no maximum group size for billing group services, except when explicitly expressed within the IEP and MPAF (for example: 30 minutes of speech services in a group setting of 3-4 students per week). The IEP and MPAF together establish what is medically necessary for the student.

Service documentation may be recorded on paper, electronically using the fillable PDFs, or entered directly into MAXCapture. All original documentation must be maintained in the case of reviews or audits. LEAs may opt to develop their own templates; however, the logs must reflect the required information contained in the DHS templates, such as indicating whether a service was delivered in person or via telehealth (and if via telehealth, whether the student was at home or somewhere other than home at the time of service delivery). Additional information about provider logs can be found in Section 4.4 of the SBAP Handbook.

When documenting services on the provider logs, it is acceptable to refer to the student as “student”, as long as that student’s name is identified on each page of the log. The student’s first and last name are required elements of SBAP documentation.

No. This is not a new requirement. Attendance records are required during audits and reviews. Below is a list of employee records that are requested by the Bureau of Program Integrity (BPI) during audits:

1. A list of SBAP employees including interim or contracted employees that provided services to the students on the attached list. For each employee (including interim or contracted employees), please provide:
   1. Job title and job description;
   2. Daily schedule;
   3. Number of hours worked per week;
   4. Number of hours worked per week per assigned student;
   5. Timecards/attendance records;
   6. Licensure/certification/CPR, etc;
   7. Supervisor’s name.

If you do not have access to these records in your role for the LEA, DHS advises you to work with other departments or administrative staff within your LEA to obtain this information.

An ICD-10 Code Crosswalk document is available in the “Resources” section of MAXCapture that was developed to aid LEAs in determining which code to use. This resource is entitled “Disability Codes to ICD10 Crosswalk.” Please note that two ICD-10 codes are used in conjunction for indication of “Deaf-blindness” (H91.3 and H54.7) and “Multiple disabilities” (F82 and F79).

The ICD-10 code is a required field for submitting services for billing through SBAP. The crosswalk document will assist LEAs in identifying the appropriate ICD-10 codes for the student. These codes do not prevent a claim from going through for billing, except when missing. However, LEAs are encouraged to take care in assigning appropriate diagnosis codes for each student for tracking and documentation purposes.

This change is due to the updated CMS guidance which was issued in May of 2023. By removing the access to exact times of upcoming moments, Pennsylvania is now in better compliance with Federal requirements. LEAs are able to run several helpful reports, such as the “No Response Report” through SSG’s e-SivicMACS to monitor moment response rates.

Additional information about the updated CMS guidance is included in the October Update document entitled “Updated Guidance from the Centers for Medicare and Medicaid Services (CMS)” available on the SBAP Website.

Moment notifications will be sent from pasbap@sivicsolutionsgroup.com. Please note that this email address is not monitored. If you have any questions to go to SSG, please contact pasupport@sivicsolutionsgroup.com. Additionally, please ensure that notifications from both of these addresses are marked as ‘safe’ by your email servers.

When certifying your staff pool list each quarter, you should always strive to assign individuals to the direct service staff pool who will deliver and bill for health-related services. You may include the PCA on the staff pool list if they are expected to provide services that are on the student’s IEP and not just educational services. If for some reason, none of the health-related services they provided could be claimed, the PCA costs are still allowed to be on the cost settlement.

Acceptable electronic signatures must include an audit trail including the person’s name who signed electronically as well as the exact date and time that the form was signed electronically. By using the fillable PDF signature field provided on the form, LEAs can easily sign this form electronically with an acceptable, auditable electronic signature.

No. Simply typing your name on the signature line and typing the date of signature does not provide an audit trail to support electronic signature. Forms submitted with a typed name and date will not be accepted.

Ideally, the MAXCapture Data Entry of Direct Health-Related Services Agreement would be signed by the same individual who signed the LEA Agreement to Participate for your LEA. Only one form is required per participating LEA and must be signed by an individual with the authority to do so.

Some examples of acceptable signers include:

• Director of Special Education
• Superintendent
• Business Manager

DHS will reject forms signed by any of the following individuals:

• ACCESS Coordinator
• Anyone not employed within the participating LEA (for example: IU staff that manage the LEA’s program)

LEAs are encouraged to complete this form and submit to DHS as soon as possible, and no later than June 1, 2024.

Simply put, anyone who has a login for the MAXCapture system must sign this form. This agreement records the individual MAXCapture user’s understanding and agreement for appropriate use of MAXCapture, which uses the individual user’s MAXCapture ID as an electronic signature within the system.

No. However, the third-party documentation system will also be recording the individual user’s ID as an electronic signature within the system. Whatever third-party system your LEA uses for electronic data entry must use a verification form that addresses all of the key requirements identified in the SBAP Handbook. It is the LEA’s responsibility to provide this verification in the event of an audit when using a system other than that provided by the Commonwealth contractor.