CCB TECHNICAL ASSISTANCE CALL July 12, :30-1:30 1

1. Maintenance of Records and Privacy Assurances 2. CCB Staff Roles 3. Procedural Safeguards 4. Confidentiality Policies 5. Individualized Family Service Plan Template 6. Upcoming Deadlines 7. Other Announcements 2

Community Centered Boards (CCBs) shall:  Establish an Early Intervention (EI) record for each child who is referred for EI Services  The record includes: ◦ Log of access ◦ Referral information ◦ Parental consent forms related to screening, evaluation and assessment ◦ Parental consent forms for accessing public and private health insurance for funding EI Services ◦ Prior written notices 3

 The record includes: ◦ Parental consent to share information ◦ IFSPs ◦ Progress and assessment reports, including child outcomes measurement information ◦ Case notes ◦ AU Notification form ◦ All correspondence related to child and family ◦ Fiscal records, including documentation of EI Service provision by qualified providers, and ◦ Any medical documentation related to the diagnosis or medical history and services 4

 All EI records are the property of the Department and shall be maintained by the CCB in a central location  Records may be stored electronically but shall be available for inspection upon request by the Department or the parent  A complete file shall be maintained of all records, documents, communications and other written materials which pertain to the operation of programs or the delivery of services for six (6) years following termination of the contract or final payment for the service, whichever is later 5

 Each CCB shall have an Early Intervention Coordinator who: ◦ Completes state-approved training ◦ Is knowledgeable of state and federal requirements ◦ Serves as the liaison with the Department regarding the EI Program ◦ Is responsible for local implementation of the EI Program and coordination with other key partners ◦ Functions as the contact for families regarding procedural safeguards 6

 Each CCB shall have an Early Intervention Data Coordinator who: ◦ Is knowledgeable of the CCMSWeb system, data entry requirements, timelines and report information ◦ Ensures that staff who enters data into CCMSWeb is trained in the use of the system and procedures to protect personally identifiable information (PII), and ◦ Ensures that all data is entered into the database per the CCMSWeb instructions 7

 Each CCB shall ensure that it has adopted a sound data security program that includes administrative, technical and physical safeguards to guarantee the privacy protections under FERPA and HIPAA  Information “at rest” and “in transit” shall be secure to guarantee that protections of PII are not violated 8

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Consent Consent shall be obtained before:  Administering screening  Any evaluation or assessment is conducted  Any Early Intervention Service is initiated  Public benefits or insurance or private insurance is used  Disclosure of personally identifiable information Can no longer use hearing procedures to challenge parent’s refusal to provide consent (including consent to evaluate) 10

CCBs shall ensure that parents of a child in early intervention have a right to confidentiality of personally identifiable information, including the right to written notice of, and written consent to, the exchange of that information among agencies. 11

 The infant or toddler’s name  The name of the infant or toddler’s parent or other family member  The address of the infant or toddler or their family  A personal identifier such as a social security number or other biometric record  Other indirect identifier, such as the child’s date of birth, place of birth, or mother’s maiden name: or  Other information that, alone or in combination, is linked or linkable to a specific child by a person in the early intervention community, who does not have personal knowledge of the relevant circumstances, to identify the infant or toddler with reasonable certainty; or  Information requested by a person who the early intervention program reasonably believes knows the identity of the child to who the early intervention services record relates 12

Who must maintain confidentiality? Any individual, agency, entity, or institution that collects, maintains, or uses personally identifiable information to implement the requirements in Part C ◦ Early Intervention Colorado/DDD ◦ CCBs ◦ Service Coordinators and Providers * Does not include primary referral sources, or public agencies (Medicaid, CHP+, and private insurance companies) that act solely as funding sources for Part C. 13

14 When does confidentiality apply?  From the time a child is referred until the participating agency is no longer required to maintain an EI record (six years) Points to remember:  Upon request an initial copy of the child’s EI records shall be made available at no cost to the parent  Access to EI records shall occur no more than ten days after the parent makes the request  All personally identifiable information sent electronically must be sent in a secure way

15  Sharing information with the AU: o For the purposes of referral, evaluation and eligibility, Child Find is part of the Part C system o When the AU is determining eligibility for Part B it is considered a separate system (even if it is the same personnel that conducted the initial evaluation) and the ability to share information changes o The CCB can share basic information with AU/CDE (between ) after parent has been given information about the opt-out policy o The CCB can share additional information such as the IFSP with parental consent

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 Delete all IFSP form templates saved from the EI Colorado website prior to 7/9/2012 ◦ All versions should be identical in content at this point  2007 version of Microsoft Word needed to use form 17

 Updated formatting of text and sections ◦ All field text boxes should have the same font type/size ◦ Present levels of Development: 2 per page ◦ IFSP Agreement page – electronic and handwritten versions are now identical format  Unlock document for footer editing ◦ Handout – visual instructions 18

1. Click “Review” tab 2. Click “Protect Document” 3. Click “Restrict formatting and Editing”

4. Click “Stop Protection”, then use ccb as the password

5. Click on Insert, then Footer, scroll down to “Edit Footer”, this will allow entry of the child’s name and date which will populate on all of the IFSP pages

6. Click here to re protect the form, using ccb as the password. Re protecting the form will allow the check boxes and text fields to work appropriately

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 ASAP – Rates for Medical, Nursing, Cued Language and Sign Language Services  August 1- Compliance and performance indicator data for Annual Performance Report (APR) and local performance reports  September 1- EI Revenue and Expenditure Reports 24

 EI Colorado moves to new Office of Early Childhood at 1575 Sherman St. in August 2012  CDHS/EI Colorado is in process of developing an RFP to examine rates for EI services and setting appropriate upper level limits by July 2013  CDHS/EI Colorado is implementing a Family Cost Participation system that includes family fees with an anticipated start date of January 2014  The IFSP and SCC training dates for the upcoming year are posted on the EI Calendar on the website  The FMAP is posted on the website and provides guidelines for reimbursable activities related to evaluation and assessment  The revised CCMS Instruction Manual is also on the website and provides instructions for entering claims data 25

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