4410/853 Schools:
SED is requesting notification that your school is closed – Providers should send an e-mail to their RA. You can site Executive Order 202.4. The notification should state you are in touch with your families and staff on a regular basis.
The Executive order only goes to April 1st and will be readdressed at that time. This is important since New York City Schools will be closed until 4/20/20.
Providers have received a waiver of the 180-day school year provision, while schools are required to be closed, it is unclear whether 1:1 aides will get paid for the 180 days. We are still trying to get an answer to how this will be resolved. Organizations will need to figure out how they are going to proceed with respect to this.
School staff should be in regular communication with families during the time the school is closed (finding out what services they need) and should be offering support, etc. They need to have a plan to work with families, be a resource, and still provide support and guidance for families. Have staff keep a log of what they are doing during the time they are working at home. Consider shipping materials to families and work with them on educating/supporting their children.
Providers should begin looking into tele-education (classroom and SEIT) and teletherapy (Related Services). These are not approved by SED at this time. However, this is the direction things are moving in, so it may be coming very soon. Schools should begin looking into developing a format for this. Not sure how this will play out.
- Take inventory of what parents have in place (computers/Internet Access)
- Consider how the platform is going to work
- What educational tools would they need
- Consider the platform you will work off (Zoom, Microsoft 365 TEAMS (corporate version is HIPAA and FERPA compliant), Google Hangouts, etc.). You must consider HIPAA and FERPA in your choices.
- May need to involve parent coaching
SEIT:
NYC DOE sent out a notice that as of today (3/18) all in-person SEIT services will be suspended until further notice within NYC. Remote SEIT services are anticipated to start the week of March 22nd. More information on how that will work is expected to be out this week. Providers will be required to maintain timesheets and submit requested progress reports and participate in CPSE meetings by phone as needed. IEP’s will not need to be updated for remote services. Parent consent forms will be required for these services.
Advocacy is occurring to find ways to ensure that providers continue to get paid even if service delivery cannot occur. Need to protect teachers and ensure child services continue even if face to face visits can’t occur.
611/619 Funds:
Programs may want to reevaluate how they are utilizing 611/610 funds. If programs had dollars earmarked for other activities (music therapy, yoga, etc.), programs might want to consider re-allocating these costs for such things as creating teletherapy programs, staff training, etc.
EI:
Approval was granted to perform Telehealth services within the EI environment through April 6th. The April 6th date is based upon the Governor’s State of Emergency (SOE). If the Governor extends the SOE, then the Telehealth would be extended.
In order to qualify:
- The family expresses a need for and agrees to use virtual EI services.
- Prior to providing Telehealth services, parent consent is necessary (specific form needs to be completed).
- Providers and families have the necessary platform to conduct virtual therapy (if the system fails and the full session is not delivered, it is not billable)
- Therapy visits cannot exceed the visits per the IFSP
- Virtual therapy must be a minimum of 30 minutes
- Providers must maintain all the required documentation of the therapy services
- Group services cannot be provided virtually, however, IFSP can be amended to reflect individual services if appropriate.
The NYC DOE has released a list of staff expectations for their school-age programs. Providers can use this as guidance in developing their own plans. Click Here.
Kenneth R. Cerini, CPA, CFP, FABFA
Managing Partner
Ken is the Managing Partner of Cerini & Associates, LLP and is the executive responsible for the administration of our not-for-profit and educational provider practice groups. In addition to his extensive audit experience, Ken has been directly involved in providing consulting services for nonprofits and educational facilities of all sizes throughout New York State in such areas as cost reporting, financial analysis, Medicaid compliance, government audit representation, rate maximization, board training, budgeting and forecasting, and more.