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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:   10        Personnel Development Standards

Related Policy  Component


Reference/Related Documents

10.1.0 General Requirements



A.      The Early Steps State Office (ESSO) will provide support and technical assistance for the ongoing in-service training of personnel providing early intervention services.

B.     ESSO will disseminate information on training opportunities for early intervention service providers and for families of children with special needs.

C.     ESSO will coordinate with the Florida Department of Education and with the Florida Interagency Coordinating Council for Infants and Toddlers (FICCIT) Personnel Training and Development Committee (PDAT) in the areas of:

1.      Establishing and maintaining standards for personnel development consistent with state approved requirements.
2.      Working collaboratively with academic, professional, training, parent and credentialing organizations.

D.     ESSO will coordinate the design, development, implementation, evaluation and tracking of training and technical assistance activities in response to systemic needs identified through the Performance Improvement process, including quality assurance monitoring and other needs assessment activities.



A.      ESSO’s personnel development system may include:

1.      Implementing innovative strategies and activities for the recruitment and retention of early intervention services providers.

2.      Promoting the preparation of early intervention providers who are fully and appropriately qualified to provide early intervention services.

3.      Training personnel to work in rural and inner-city areas. 

4.      Training personnel to coordinate transition services for infants and toddlers with disabilities from an early intervention program to a preschool program under IDEA, Part B or to other preschool or other appropriate services.

B.   ESSO will develop partnerships to increase training opportunities and strengthen collaborative training efforts. Partners may include: LES, DOE, LEAs, Institutes of Higher Education (IHE), Early Learning Coalitions, Agricultural Extension Programs, Agency for Workforce Innovation, Centers for Autism Related Disorders (CARD), Local Children’s Services Councils, Early Head Start, Head Start, Healthy Start, Technical System and Training System (TATS), and others as identified.


10.2.0 Local Early Steps (LES) Requirements



Each LES will disseminate training information to local providers.

A.      Each LES may elect to require additional training beyond the minimum training standards set forth by ESSO.

B.     Each LES will collaborate on training content with the ESSO.


10.3.0  General Requirements for Provider Application and Approval


The CMS/ES Provider Management System approves individual, independent providers; CMS does not approve provider agencies.


10.4.0 Service Coordinator Requirements


After a service coordinator is hired, the following will occur:

A.      The LES will verify the degree is from an accredited university by checking the following website:

B.     After checking and completing all attestations, the LES will forward the completed LES Service Coordinator Attestation Checklist to the ESSO.

C.     All hard copy documents that verify a service coordinator meets the stated service coordinator criteria will be maintained by the LES.

D.     Upon receipt, ESSO will review and sign the LES Service Coordinator Attestation Checklist if all requirements are met and will return the checklist to the LES.  This attestation checklist will serve as a recommendation to Medicaid Provider Enrollment that all CMS Early Steps requirements are met and the service coordinator should be approved as a Medicaid TCM provider. 

E.     The newly hired service coordinator will apply directly to Medicaid Provider Enrollment, to become a Medicaid Targeted Case Management Provider. It is highly recommended that an electronic application be sent to expedite approval.  Scanned documents can be uploaded with electronic applications and attached. The Medicaid Targeted Case Management checklist may be used to ensure the application includes all required documentation.

F.      It is the LES/provider’s responsibility to send the attestation checklist along with their Medicaid Application to Medicaid Provider Enrollment. 

G.     After the LES has attested to all items on the LES Service Coordinator Attestation Checklist and the service coordinator has completed the apprenticeship, the LES will forward the following information to the ESSO data manager.

1.      Enrollment Status (New Enrollment, Update Provider, Termination)

2.      Last Name

3.      First Name 

4.      Middle Initial

5.      Address 1

6.      Address 2

7.      City

8.      State

9.      Zip Code

10.  County

11.  Telephone

12.  Fax

13.  Email Address

14.  NPI Number

15.  Last Name of person submitting information

16.  First Name of person submitting information

17.  Service Area of person submitting information

18.  Telephone Number of person submitting information

19.  Email Address of person submitting information

20.  Attestation of completion of apprenticeship

H.     The ESSO Data Manager will then enter the service coordinator in the Early Steps data system as fully approved.

Medicaid Targeted Case Management Checklist




A.      The service coordinator’s employment record maintained by the LES will be used to verify experience.  A certification of experience form is not required.

B.      One year of professional experience equals 1600 hours of hands-on experience.

C.     Time spent in a practicum or internship situation (up to 400 hours) may apply toward the 1600 hours of hands-on experience.



A.      At the beginning of the apprenticeship process, the Service Coordinator Self-Assessment may be used as an optional tool to identify knowledge and skills that need to be attained or enhanced during the apprenticeship.

B.     Apprenticeship activities will be documented on the Early Steps Service Coordinator Apprenticeship Checklist.

C.     The Service Coordinator Apprenticeship Checklist is to be maintained by the LES and may be subject to random audit.

D.     Practicum or internship experiences completed in a Local Early Steps within the past 18 months, which match those of the apprenticeship, can be applied to the apprenticeship requirements.

LES Service Coordinator Attestation Checklist

Service Coordinator Self-Assessment (optional)


Medicaid allows Medicaid-enrolled targeted case managers to also be the primary service provider for the same child and allows Medicaid billing for both services.  Medicaid rules for documentation and billing must be followed.



When a service coordinator is dually enrolled and serving a Medicaid child, the Medicaid Freedom of Choice form must be signed by the parents.

Medicaid Freedom of Choice Form

Medicaid Freedom of Choice Statement Checklist

10.5.0  Licensed Non-Physician Healthcare Professional (LHCP) Personnel Standards


It is recommended that any Licensed Healthcare Professional who enrolls as an Early Steps provider enroll in both the Medicaid program for their discipline and as a Medicaid Early Intervention (EI) service provider so that they may participate in and bill Medicaid for early intervention evaluations.





The supervising therapist of a therapy assistant is a member of the IFSP team.


10.6.0   Non-Licensed Healthcare Professional Personnel Standards


A.      Medicaid requires that an Infant Toddler Developmental Specialist (ITDS) who is serving a child who receives Medicaid, receive support and direction from a Licensed Healthcare Professional. This must include at least one face-to-face meeting between the ITDS and LHCP every six months which occurs either through consultation at team meetings or through joint visits with the child and family.

B.     The above requirement is consistent with the Early Steps team based primary service provider approach for the provision of services in which each child/family is supported by a team and the team provides support and direction to service providers.  Support and direction, which is not synonymous with supervision, is provided through consultation and joint visits that are both planned (documented on the IFSP) and spontaneous opportunities. 


Florida Medicaid Memorandum, November 14, 2007



The ITDS enrollment process will be implemented as follows:

A.      The LES Director/Coordinator or the LES designee will mail, email or fax an ITDS Enrollment Packet to the Early Steps Training Unit Director at ITDSWaivers@doh.state.fl.usThe ITDS Certificate Request Checklist may be used to ensure that the packet contains all required information.  The ITDS Enrollment Packet must include:

1.  Cover Letter with:

a.      Applicant’s full name, middle initial, date of birth and social security number.

b.      Identification that the applicant is either an ITDS coursework graduate, a hardship waiver applicant or designated as highly qualified.

c.      Degree, major and number of years of experience.

2.      Copy of degree and/or transcript. The transcript is required for an out-of-field or equivalent degree, or if the copy of the degree doesn’t specify the major.

a.      The LES should verify that the degree require­ments, including university accreditation, are met by checking the following website:  If the college or university is accredited by an organization and is not listed on this website, verification of accreditation must be included in the packet.

b.      In order for their degree to be considered “equivalent”, the applicant:

                                      i.     Must have completed a minimum of 18 credit hours (typically six courses) in one of the fields listed in the Florida Medicaid Early Intervention Services Coverage and Limitations Handbook.

                                     ii.     Will be required to submit their transcript and/or a catalog description from the university or college as verification.

                                   iii.     May use placement, internship or practicum hours to meet either the education require­ment or the experience requirement, but not both.

3.      Documentation of Professional/Post Degree experience.  An ITDS applicant with:

a.          An in-field or equivalent degree must provide documentation of one year of post-degree professional experience in early intervention using the Early Steps Certification of Experience form.

b.          An in-field or equivalent degree who cannot document one year of post-degree professional experience must provide a statement of their intent to complete the Early Steps mentorship requirements.

c.          An out-of-field degree must provide documentation of at least five years of post-degree professional experience in early intervention using the Early Steps Certification of Experience form.

4.      Verification of one of the following:

a.      The applicant has successfully completed the university ITDS coursework at an approved university as documented by a university letter or transcripts.

b.      The applicant meets the hardship waiver criteria as demonstrated by submission of the information specified in 10.6.5 below.

c.      The applicant meets the criteria to be highly qualified as demonstrated by submitting the information specified in the Early Steps section of the CMS Provider Handbook - Non-licensed Healthcare Professionals and also indicated on the ITDS Certificate Request Checklist.

B.     When a completed ITDS Enrollment Packet is received at ESSO, a review committee is convened.  The review committee consists of the Early Steps Training Unit Director or designee and the Program Manager of the LES submitting the request.

C.     The committee reviews the ITDS Enrollment Packet and will recommend that the request be either approved or denied.  The Early Steps Training Unit Director makes the final decision.  The Early Steps Training Unit Director or designee will notify the LES Director/ Coordinator or LES designee of the decision via email within 14 calendar days.

D.     If the request is not approved, the ITDS Enrollment packet is scanned, encrypted and kept on file electronically at ESSO for 12 months.  The hard copies of the ITDS Enrollment Packet will be shredded.

E.     If the request is approved, the applicant must complete the ITDS online modules within 30 calendar days of receiving approval. If the modules are not completed within 30 calendar days, the packet will be returned to the LES Director/ Coordinator or the LES designee.  The applicant must reapply to be considered for ITDS enrollment in the future.  An applicant who has provided verification from a university stating successful completion of university ITDS coursework will be approved as an ITDS and is not required to take the ITDS online modules. 

F.      It is the responsibility of the LES Director/Coordinator or their designee to notify the Early Steps Training Unit Director by email that the modules have been completed within the 30 calendar day timeline. 

G.     After the Early Steps Training Unit Director or designee verifies completion of the modules or successful completion of the ITDS coursework, an ITDS Certificate will be emailed to the LES Director/Coordinator or their designee.  The ITDS Certificate will be included in the ITDS Enrollment Packet and delivered by ESSO to the CMS Provider Management Unit.

H.     When a credential/certificate is from another state, it may be considered as equivalent to the Florida ITDS Certificate if coursework and/or equivalent online modules are compatible with that required by Florida.

1.      The applicant must submit their transcript to the LES and may also be required to submit a catalog description from the university or college. 

2.      The ESSO will compare the transcript and/or catalog coursework description from the university or college to the Florida ITDS competencies, and attest that the applicant’s online coursework is compatible with that offered in Florida.

I.         After receiving the ITDS Certificate, the applicant must submit an online application at to continue enrollment in the CMS Provider Management System.  Approval to take the online modules does not constitute approval as a CMS provider. All other requirements outlined in the CMS Provider Handbook for Non-licensed Professionals must be met.

J.       When the applicant receives an ITDS Certificate, they must also apply for enrollment with Medicaid Provider Enrollment at
. The applicant must include the ITDS certificate with the application.

CMS Provider Handbook - Non-licensed Healthcare Professionals


In order to maximize third-party resources and comply with IDEA, Part C payor of last resort requirements, the LES should encourage non-licensed providers to dually apply to be approved as an Infant Toddler Developmental Specialist if they meet the personnel standards for the ITDS, which includes enrollment in Medicaid as an early intervention services provider. 



A.      Applicants requesting an ITDS Workforce Hardship Waiver must include the following with their ITDS enrollment packet cover letter:

1.      Applicant’s full name, middle initial, date of birth and social security number.

2.      Clearly identified degree, major and number of years of professional experience.

3.      Documentation of workforce hardship as specified below:

a.      Statement of need that includes a description of current workforce and the number of enrolled ITDSs for that service area.

b.      Need for additional ITDS providers.

c.      Description of ITDS recruitment efforts by the LES.

d.      Justification for submitting specific individual for waiver such as fluent in other languages, willingness to serve in a rural area where there is a shortage of ITDSs, etc.

B.     All other submission requirements are the same as those listed in 10.6.3 above.  All other requirements outlined in the CMS Provider Handbook - Non-licensed Healthcare Professionals must be met.



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