With the forthcoming CDE Implementation requirements for California LEAs, we want to discuss billing for nursing services. Practi-Cal has the only documentation system that includes full management, recording and reporting to meet CDE documentation requirements. One area that we have already noticed outliers, is the over recording of IEP nursing services to CALPADS code 435.
There are times when nursing services are not listed in the student’s IEP, but are authorized in a separate care plan. However, when treatments are documented, we are seeing nurses, LVNS, and Health Aides documenting the services as an IEP promised service, which is leading to the minutes being over-recorded to CALPADS code 435.
Practi-Cal is recommending that nursing services that are NOT listed in the IEP be recorded as Non-IEP services. This will make CDE reporting more accurate for your LEA.
Nursing and healthcare staff will still need to have a care plan on file, medical authorization, and maintain service documentation. The rates are the same as IEP services, so there will not be any drop-off in reimbursement. Here are the scenarios:
- Student has a medical service (i.e. CALPADS Code 435) listed in the IEP. In this case, the services should be recorded as “IEP” in SpEdCare and recorded minutes should be in accordance with the promised frequency and duration noted in the IEP.
- Student has an IEP, but the service (I.e. CALPADS Code 435) are not listed in the IEP. In this case, the services should be recorded as “Other (IHP, 504, Counseling, etc.)” in SpEdCare.
- Student does not have an IEP, but has a care plan for medical services. In this case service should be recorded as “Other (IHP, 504, Counseling, etc.)” in SpEdCare.
To ensure accurate recording, we recommend that health staff record services consistent to the plan the medical services are promised. This may be the IEP or separate care plan. If you have questions concerning this process, please contact your assigned Practi-Cal consultant.
Recording services consistent with the plan type will make passing an audit easier.
- If the medical service is not listed in the IEP, services must still be covered by an acceptable written care plan (i.e. IHP, 504, Counseling, etc.).
- If the medical service is not listed in the IEP, but recorded as an “IEP” service, the auditor can then request the IEP as a source of supporting documentation. In this case, there would still need to be an acceptable care plan to cover the medical service, as the IEP would not suffice.
- The care plan, must also have ORP (Ordering, Referring, and Prescribing) professional’s authorization.
We recommend using our Care Plan Writer module to develop compliant care plans, even when services are promised on an IEP, as the ORP professional does not sign the IEP.