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Early Steps Operations Guide

This document does not include guidance/procedures for each policy in the Early Steps Policy Handbook.  Guidance is included only as necessary to explain how to implement a policy, outline steps, or recommend actions to support implementation.

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Component:   1.0       General Supervision and Administration

Related Policy  Component


Reference/Related Documents

1.1.0 General Authority


ESSO may convene internal workgroups as necessary to assist in carrying out administrative functions.  Membership in internal workgroups will include individuals who work within the Early Steps system such as ESSO staff, LES directors, LES service coordinators, and LES data center staff.  An internal workgroup may be task-oriented or on-going. 

A.    Task-oriented internal workgroup is time limited.

1.      ESSO will ensure that the assigned task and timelines for completion are clearly articulated to the group.

2.      Volunteers for the workgroup will be solicited.

3.       Bureau chief will appoint the chair or allow the group to identify the chair.

B.     On-going internal workgroup meets on a periodic and continuous basis to provide advice or input on a focused aspect of the ES system, such as data or service coordination.

1.      Bureau chief will either appoint chair or allow the group to identify chair.

2.      A mission statement for the workgroup is developed with the scope and objectives of the workgroup delineated in writing.  

C.     Workgroup chair responsibilities:

1.      Ensure membership of the workgroup appropriately represents potential stakeholders.

2.      Coordinate and preside over group activities, schedule meetings in advance and designate a note taker.

3.      Establish a directory at G:\Early Steps\Workgroups\Internal Work Groups\work group name for filing of all agendas, minutes and products.

4.      Ensure that draft notes are disseminated via e-mail to members and final notes are added to workgroup directory.

5.      Present written reports and recommendation to bureau chief.

D.     Development of workgroup reports and recommendations.

1.      Reports will outline specific proposed actions for ESSO, LES or others, as appropriate.

2.      Recommendations related to Early Steps policy, operational procedure or contract provisions will include specific references to existing policies and procedures to be impacted.

3.      Proposed timelines for implementation of recommendations will be included.

4.      Reports and recommendations will be clearly marked as “DRAFT—for Discussion Only” during the development, review and input period, until ESSO action is finalized.

E.     Review of workgroup reports and recommendations.

1.      Bureau chief will forward reports to management team for review.

2.      Unit directors or designees will present report for review by unit staff for input and recommendations.

3.      Unit directors will present staff input and recommendations to the Early Steps management team.

4.      Early Steps management team will present to bureau the combined input and recommendations from staff.

































1.2.0 Requirements for a Statewide System under Part C of the IDEA


Appropriate groups that would provide assistance to infants and toddlers with disabilities and their families may include public and private early intervention services, resources, and experts available in the state as well as parent support and training and information centers.



A.      External workgroups are those convened by the ESSO that include stakeholders, or individuals who are not working internally for the Early Steps system.  When convening an external workgroup, the ESSO will ensure that:

1.      The task(s) that the workgroup is expected to complete will be clearly articulated in writing prior to the first meeting of the group.

2.      Timelines for completion of the work assigned to each workgroup will be clearly articulated in writing.

3.      A workgroup chairperson, responsible for coordinating and presiding over the group’s activities, will be identified by CMS prior to the determination of workgroup membership.

4.      The workgroup chair will be selected considering a number of factors, including expertise and facilitation skills.

5.      Each workgroup will have at least one ESSO staff person identified as a participating member and who will serve as the liaison between the group and the ESSO.  The ESSO representative will be appointed by the ESSO bureau chief.

6.      In addition to the ESSO representative(s), primary constituencies represented on workgroups will include individuals from the list below.  At the discretion of the ESSO, the constituencies represented will be expanded or limited depending on the task/focus of the group.

a.      LES directors/coordinators

b.      Families/caregivers

c.      Florida Interagency Coordinating Council for Infants and Toddlers (FICCIT)

7.      Primary constituency groups will be asked to nominate individuals to represent their constituency on the group and provide the names of individuals to the workgroup chair.

8.      The workgroup chair will submit names of workgroup members to the Early Steps bureau chief.

9.      All workgroup members (including the ESSO representatives) will be informed of their responsibilities as a workgroup member and that they are serving as representatives of their “constituent group” and have a responsibility to share information about the activities of the workgroup with members of their constituent group and provide a mechanism for feedback from the constituents to the workgroup.

B.     External workgroups convened by the ESSO will carry out the following responsibilities:

1.      In addition to generally coordinating and presiding over the group’s activities, the workgroup chair must provide reasonable notice of all workgroup meetings regarding whether meetings are held via face-to-face contact, conference call, videoconference, or situations in which the workgroup solicits input via e-mail.

2.      The workgroup chair will select an individual to perform the role of note-taker during workgroup meetings.

3.      The ESSO representative on the workgroup will establish a directory at G:\Early Steps\Workgroups\External Work Groups\work group name for all agendas, minutes and products of the workgroup.

4.      Following each meeting, notes will be disseminated to all workgroup members for review and input and will be clearly marked as “Draft -- for Discussion Only”.

5.      When meeting notes are disseminated to workgroup members, they will be reminded of their responsibility to disseminate information to and obtain feedback from their constituents.

6.      When approved by the workgroup, final notes from workgroup meetings will be posted on the Early Steps website within 14 calendar days following approval.  The ESSO representative will ensure that the notes are posted on the website.

7.      Meeting notes will be reviewed by the appropriate supervisor/unit director prior to posting on the website, as required by Early Steps web posting guidelines.

8.      All posted meeting notes will include information on who members of the public should contact (and how to contact) if they want to provide direct input related to the activities of the workgroup.

9.      Face-to-face workgroup meetings will be held in locations where members can most easily and economically attend.

10.  The workgroup chair will be responsible for presenting a written report to the ESSO bureau chief within the established timelines, including a list of recommendations related to the assigned task(s) /issues.

11.  The workgroup report will outline specific proposed actions for ESSO, LES or others, as appropriate.

12.  The workgroup report will include proposed timelines for implementation of recommendations, as appropriate.

13.  When the workgroup report includes recommendations to change an Early Steps policy, operational procedure or contract provision, the report must specify which policy, operational procedure or contract provision is recommended to be changed.

14.   All workgroup recommendations will be clearly marked as “Draft -- for Discussion Only” throughout the development, review and input period, until the ESSO takes action on the recommendations.

C.     Following receipt of an external workgroup report:

  1. The ESSO bureau chief will forward the workgroup report to the management team for review.
  2. Unit directors will present the workgroup report for review by unit staff and request input and recommendations from staff.
  3. Unit directors will present staff input and recommendations to the Early Steps management team.
  4. The Early Steps management team will present to the bureau combined input and recommendations from staff across units.

5.      By consensus, the ESSO will make recommendations and/or decisions regarding workgroup recommendations.

6.      The Early Steps bureau chief will communicate in writing to the workgroup chair within 14 calendar days of the decisions made by the ESSO and will specify which recommendations have been accepted and will be implemented, which recommendations have been rejected/denied, and which recommendations require additional information/ clarification prior to the ESSO reaching a decision.

7.      The division director for CMS Network and related programs and the deputy secretary for CMS will be involved in decisions regarding workgroup recommendations, which are considered “high risk”.  A high risk decision includes one of the following circumstances:

a.      The agency head, governor, or legislature has asked for a particular position or policy.

b.      A recommendation impacts the children and families served by Early Steps in a negative way.

c.      A recommendation would change the Early Steps service delivery model.

d.      A recommendation would have a negative financial impact.

e.      A recommendation involves any controversial/ liability situation.

8.      Prior to implementing a change in policy related to IDEA, Part C as a result of a workgroup recommendation, the ESSO will ensure public review and comment as required by the IDEA, Part C.

9.      In rare circumstances, such as time constraints, a decision may be made without input and recommendations of one of the individuals/groups specified above; however, a summary of such will be presented to the Early Steps bureau, division director or deputy secretary as soon as possible to make them aware of the circumstances of the decision.














































































The purpose of child find is to ensure that potentially eligible children with disabilities and their families are informed of the availability of services under IDEA, Part C by the agency or agencies responsible for administering the IDEA, Part C program in the state.



The procedures for resolving conflict include the right to an impartial hearing, administrative appeal, civil action and mediation in order to resolve individual child complaints.



If the LES contracts with an agency that employs enrolled individuals, the contract holder in turn may contract or make other arrangements with local service providers to provide direct services to eligible infants and toddlers and their families.



The Florida Legislature makes a specific annual appropriation for Early Steps.  Early Steps legislative appropriations include state funding for the program and budget authority for spending federal grant funds.  Local funds will be accessed by LES.


1.4.0  Financial Policies and Procedures


  1. The LES must identify all additional potential funding sources for early intervention services and supports, including third party revenues, local school district funding and local/community funding resources.
  2. The Local Early Steps will develop a plan for accessing and using additional funding sources to ensure the provision of IDEA, Part C services to eligible children.  The annual Early Steps spending plan may address the following:
    1. A process for projecting the use of direct service dollars based on historical service patterns.
    2. A process for periodically projecting service costs, projecting surplus or shortfall and responding to financial or other service delivery crises.
    3. A process for identifying and accessing other funding sources for early intervention services and supports, such as community funds, grants and in-kind contributions.
    4. Procedures for ensuring IDEA, Part C funds used to fund services for children over age three do not exceed three months and the use of funds is justified on the Individualized Family Support Plan.
    5. Emergency payment procedures.
  3. Once this information has been obtained, a LES representative should record/compile information for each insurance company.
  4. If the insurance network provider is not an enrolled Medicaid Early Steps provider, the LES should contact the provider to encourage the provider to enroll in the Early Steps network.  If the provider does not choose to enroll as an Early Steps provider, the LES representative should discuss Early Steps expectations regarding payment for services with the provider. The LES may have to make individual decisions regarding the cost benefit of having the family use the insurance network provider and paying the co-pay or deductible and potentially the additional costs (difference between insurance payment plus co-pay/deductible and provider’s usual and customary charge) or having to use Early Steps funds to provide the service.  In some situations, it may be less expensive to the LES to access the child’s insurance and pay the “additional” costs than to not use the insurance and have to pay 100% of the service cost to an enrolled provider. 




Medicaid and/or financial status are not eligibility criteria for early intervention services.  Children eligible for IDEA, Part C need early intervention services because they have a developmental delay or established condition with high probability of resulting in developmental delay. 

Although not required, it would be appropriate for the service coordinator to provide information and/or assistance to the family in making application for Medicaid or other benefits to ensure that IDEA, Part C funds are used as last resort.




When a child is enrolled in the Medicaid program and the service to be provided is a Medicaid reimbursable service and the child’s IFSP team recommends a level of service provision which exceeds the Medicaid service limitations, then the child’s service coordinator or service provider must ensure that the Medicaid service exception procedure is followed to obtain Medicaid payment approval for the service prior to accessing IDEA, Part C funds. 




It is critical that all options are explored before using IDEA, Part C funds for an early intervention service that is covered by a third party payer.  This should include pursuing other funding sources for which infants, toddlers and their families might be eligible, such as Medicaid, CHAMPUS/TRICARE, and services for children with special healthcare needs through the CMS Network.




Prior to a provider being chosen for an authorized service, the service coordinator and/or a LES representative  should, with the family’s consent, contact the family’s insurance company and determine whether or not a provider is available, able to provide services in the natural environment and covered under the insurance plan. Only after such a provider is ruled out, can IDEA, Part C funds be used to pay for the authorized service.

In order to have providers that meet the needs of Early Steps, providers should be recruited who are knowledgeable about the benefits of providing early intervention services in natural environments and who are willing to travel to natural environments.




A.       LES payment of co-payments or deductibles should not cause the total payment for the service rendered to exceed the Early Steps allowable rate for the service.

B.       Families should be asked to provide periodic documentation regarding their insurance deductible balance since other medical or health services can be applied to a child or family’s deductible obligation.




Federal regulations allow states a 27 month period in which to expend all IDEA, Part C funds granted within a particular fiscal year. 



1.6.0  Use of Public and Private Insurance



  1. The LES may choose to designate someone other than the service coordinator to discuss the use of insurance with the family, but the service coordinator maintains responsibility to serve as the single point of contact in helping families obtain needed services. The LES may use local discretion and determine the service coordinator’s level of involvement with insurance companies.
  2. When the family has public or private insurance, the LES representative should, with the family’s consent, contact the family’s insurance company to determine the following information:       
    1. Will evaluation/assessment services apply to the lifetime policy cap?
    2. How much is the family policy cap?
    3. What is needed in order to get evaluation services covered (e.g., physician’s referral)?
    4. What types of early intervention services, therapies, and other services are included in the benefit package and are there service requirements or limitations?
  3. The discussion regarding the use of family insurance may also include what information is required to show that IDEA, Part C is payor of last resort.




When the IFSP indicates that the family’s insurance carrier will be the payer for services, a written denial on company letterhead or an Explanation of Benefits (EOB) received by the provider is required to show that IDEA, Part C is payor of last resort.  When neither of these can be obtained, the LES may accept the insurance company’s written policy or statement of benefits as documentation that certain service are not covered by the policy or that the policy pays for a limited number of sessions.  If a written statement of benefits is used, the LES must confirm this information with the insurer. It is not necessary for the LES to pursue insurance company reimbursement for services provided by an ITDS.




If the insurance company’s policy requires reimbursement for a service only under certain circumstances (e.g., 3 times within the period of a month), this information should be kept in the child’s record as back-up documentation when a denial is received and further denials during this time period are not required. 



A.   The following guidelines can help speed up the claims process. The parent should:
1.      Inform the insurance company about a claim in writing within 20 days. The parent must file the claim within 90 days.
2.      Fill out all forms accurately and completely.
3.      Ensure that all copies of bills are attached to respective forms, if requested.
4.      Sign all documents.
5.      Maintain copies of everything sent to the insurance company.
B.      The insurance company should pay the claims promptly after it receives the completed claim form.  The insurance company should also provide an explanation for a partial payment or a rejected claim. If a claim is denied, an appeal may be filed.

C.     If there are disputes with an HMO or agent, the Department of Financial Services can help resolve the situation by presenting concerns to the HMO or agent, or by suggesting actions that can be taken by the individual.  While the Department of Financial Services may ask the HMO to reconsider its position when the facts of a situation are in doubt, the department cannot make a final determination about the facts of a situation or act as legal representative for the individual.

D.     Steps that can be taken to lower the chances of a claim being denied:

1.      Know before receiving treatment what the health insurance will and will not cover.

2.      Make sure that pre-authorization requests contain correct patient information. Insurers often return or deny pre-authorization requests because of missing data. The physician will need to request the pre-authorization for the individual, or at least provide all necessary medical documentation.

3.      Document all communication involving any health insurance problem or question, including the names of people contacted, when they were contacted, and photocopies of any paperwork. 

The Florida Department of Financial Services: Health Insurance: A Guide for Consumers

Florida Department of Financial Services: HMO Health Maintenance Organization: A Guide for Consumer




When the insurance company provides payment directly to the parent, and the service provider encounters difficulties in obtaining payment from the parent, it is recommended that a certified letter be sent to the parent explaining participation in Early Steps, the requirements of payment, the use of IDEA, Part C funds as payor of last resort, and their consent for use of their family’s insurance.  It is suggested that the parent be informed that they are not entitled to reimbursement of benefits for services that they did not pay for and that the money is owed to the provider. The letter may state that if payment is not rendered, the service provider's only recourse would be to pursue a claim in small claims court. 

The LES or the service provider may have the parent sign an Assignment of Benefits form as part of the enrollment process or after the IFSP has been developed. The LES or service provider may develop their own form.


Use of Medicaid


Not all service coordination activities are reimbursable as Medicaid Targeted Case Management services. 

The LES should conduct a periodic review and research of the Errors on Billing report provided by Medicaid that indicates the number of claims paid, suspended or denied, in order to ensure that Medicaid billable services are appropriately billed and collected.



The reimbursement amount for Medicaid HMO's should be considered payment in full if the reimbursement is for the actual amount of service allowable. 



Exceptions to exceed the rates shown on the Early Steps Service Code Taxonomy are allowable as long as procedures listed in the EI Program Data and Reporting Handbook are followed and an exception report is submitted along with the fiscal report submitted with the LES contract invoice to ESSO. 

The listing of services and payment rates for Early Steps is included in the Early Steps Service Code Taxonomy.





1.7.0  State Interagency Coordinating Council


Refer to FICCIT-stipends documents.



1.8.0.  Monitoring, Technical Assistance and Enforcement


A.      Priority areas shall include:

1.      Provision of services in the natural environment.

2.      Exercise of general supervision authority in areas of child find, use of resolution sessions/mediation/ voluntary binding arbitration, and transition.

3.      Disproportionate representation of racial and ethnic groups in Early Steps, to the extent representation is the result of inappropriate identification.

4.      Other data.

B.     The IDEA, Part C State Performance Plan (SPP) and Annual Performance Report (APR) will report data based on indicators addressing the priority areas outlined by OSEP. The data may come from Early Steps records review and other indicators of performance.  The IDEA, Part C Indicator Measurement Table provides guidance for measuring the priority areas and indicators outlined by OSEP.









SPP/APR Calendar






Correction of noncompliance means that ESSO will require LES and providers to revise any noncompliant policies, procedures and/or practices and ESSO will verify through follow-up review of data, other documentation (including Early Steps records) and/or interviews that the noncompliant policies, procedures, and/or practices have been corrected.



The LES may review the performance standards stated in the LES contract and procedures outlined in the current IDEA Part C State Performance Plan (SPP) and IDEA, Part C Annual Performance Report for further information.




During interim years, the annual performance report will be completed and submitted to U.S. DOE/OSEP for review.



ESSO may consider the following in making determinations:

A.       Performance on compliance indicators.

B.       Whether data submitted by LES programs is valid, reliable, and timely.

C.      Uncorrected noncompliance from other sources.

D.      Audit findings.

E.       History, nature and length of time of any reported noncompliance.

F.       Evidence of correction, including progress toward full compliance.

G.      Special conditions.

H.       Compliance agreements.

I.          Verification or focused monitoring findings.

J.        Performance on performance indicators.

K.        Other information.




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