Audit season is in full swing and it is important to have the district documentation ready in the event you are selected.
ONWARD urges all school districts to ensure the following information follows compliance requirements.
- Documentation is adequate to support the services reimbursed for Medicaid.
- The sessions reported for SHARS reimbursement is supported by the IEP/ARD documentation.
Below are the top 5 most audited areas of a school district’s SHARS program.
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Personal Care Services – Documentation is adequate to support the service billed.
- SHARS service logs document Personal Care Services that are listed in the student’s IEP.
- The SHARS service log contains all elements required by Medicaid including, date of service, procedure code(s), notation of activities provided, provider observations of the student during the session, start and stop time, total billable minutes.
- If Group PCS is documented for an entire day, the IEP must be consistent with the student’s functional capacity.
- Documentation indicates PCS is appropriately billed when a student was absent for partial day or full day on the reported date of service.
- The student’s IEP that prescribes PCS services are accurately reported on the SHARS service log.
- SHARS service logs are signed and dated appropriately within 7- calendar days of the date of service.
Defined by HHSC, services to teach a student skill to facilitate independent living, such as housework/chores, grocery shopping, meal preparation, job training, communication, money management, social skills, art/music therapy, sign language and laundry skills may be considered PCS (instrumental) activities for daily living, however may more appropriately addressed the student’s curriculum. PCS should be provided to help a child with a disability or chronic condition benefit from special education. The goal of PCS in the school setting is not to teach or habilitate, but to complete the activity. In addition, although the student’s ARD includes annual goals and short-term instructional objectives and/or daily living/self-help skills, these are not considered PCS in the school setting; but rather teaching
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A signed copy of the IDEA-B Parental Consent form must be produced in an audit.
A public entity must obtain parental consent before releasing a child’s personally identifiable information for billing purposes to a public benefits or insurance program for the first time. The term “assumed consent” without an actual signed Medicaid Parental Consents is not in compliance with federal law.
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A copy of the clinician/provider/therapists’ credentials and/or licensure to show a current certification.
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System processes for the validation of electronic signatures
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Valid Occupational Therapy and Physical Therapy Physician Prescriptions
A prescription is required for OT and PT services. The prescription must be updated a minimum of one time every three calendar years. OT and PT services must be prescribed by a physician or other eligible prescribing provider. A prescription for OT and/or PT services must be signed and dated within three calendar years before the initiation of services.
OT and PT services may be reimbursed up to (but not to exceed) the amount designated in the prescription. In order for OT or PT services to be reimbursed through SHARS, the name and national provider identifier (NPI) of the licensed physician, or other eligible prescribing provider, must be listed on the claim and kept in the medical record.
Audit Record Retention
Student-specific records that are required for SHARS become part of the student’s educational records and must be maintained for seven years. All records that are pertinent to SHARS must be maintained by the LEA until all audit questions, appeal hearings, investigations, or court cases are resolved. Records must be stored in a secure and readily accessible location and format and must be available for state or federal audits.
The following is a checklist of the minimum documents to collect and maintain:
- Signed consent to bill Medicaid by parent or guardian
- IEP
- Current provider qualifications (licenses)
- Attendance records
- Prescriptions and referrals
- Medical necessity documentation (e.g., diagnoses and history of chronic conditions or disability)
- Session notes or service logs, including provider signatures, for each service/event
- Supervision logs
- Special transportation logs
- Claims submittal and payment histories
- Assessments/evaluations
- Written agreements (contracts) for contracted service providers
- Copies of signed Certification of Funds (COF) letters and supporting documentation, including quarterly COF reports
- E-signature authorization forms(s) if applicable
For more information on SHARS audits, contact your ONWARD Account Manager or check out the Audit Prep Paperwork available to district SHARS Administrators in the ONWARD system. We are here to help!