B. DOCUMENTATION REQUIREMENTS

 

B1. How long do SHARS providers need to keep their records?

SHARS records need to be retained for at least seven years because they are both Medicaid and educational records. Medicaid records must meet federal retention guidelines and, as such, must be maintained for a minimum period of five years from the date of service or until all audit questions, appeal hearings, investigations, or court cases are resolved. The federal guidelines governing public education require records to be stored for seven years. SHARS providers must maintain records as outlined in the TMPPM in the Provider Enrollment and Responsibilities Section and the SHARS Section, which meet the federal retention guidelines.

See also response to B10

B2. Where must records be kept for audit purposes?

Records must be stored in a readily accessible and secure location and format. If a SHARS audit is conducted, a school district will usually be allowed up to ten business days to provide the requested documentation. SHARS records must be maintained until all audit questions, appeal hearings, investigations, or court cases are resolved. School districts should maintain written procedures regarding the minimum documentation requirements and where those documents are stored.

B3. What records should be maintained?

At a minimum, the following is a suggested checklist of documents related to the SHARS direct services that were provided which should be collected and maintained for SHARS documentation, this is not an all-inclusive list:

  • Signed consent to bill Medicaid by parent or guardian
  • ARD/IEP documents (medical necessity; examples of SHARS services)
  • Attendance records
  • Assessment/evaluations
  • Current provider qualifications (current licenses and certifications)
  • Written agreements (contract) for contracted service providers
  • Required prescriptions or referrals for services
  • Medical necessity documentation (e.g. diagnoses and history of chronic conditions or disability)
  • Supervision logs
  • Session notes or service logs, including provider signatures
  • Transportation documentation (daily trip logs; maintenance logs/records; bus documentation; documentation for cost report)
  • Claims Submittal and Payment Histories (R&S Reports and General Ledger)
  • Copies of signed/notarized quarterly Certification of Funds (COF) letters and supporting documentation, including quarterly COF Reports
  • Non-school SHARS provider affiliation letter and attachments (if applicable)

At a minimum, the following is a suggested checklist of documents related to the SHARS Cost Report which should be collected and maintained for SHARS documentation, this is not an all inclusive list:

  • Cost Report
  • Cost Report supporting documentation

NOTE: The child’s name and Medicaid number should appear on every page of the medical records (see the Provider Enrollment and Responsibilities Section of the current TMPPM). This would include each page of the ARD/IEP document, session notes and service logs, and evaluations.

For detailed instruction regarding specific Cost Report documentation refer to: SHARS Website.

B4. Should the individual service provider (i.e., speech therapist, LSSP, nurse) or the school district retain all files and records on a child including session notes? 

Yes, the SHARS provider is the school district. It is up to the school district where the documents are stored; but, the documents must be readily accessible to submit to the state upon request. See also the response to B2.

B5. What documentation is necessary to bill for contracted services?

The same documentation is required to be maintained by the school district for contracted services as is required if the services were delivered by school employees which would include a copy of the signed contract, copy of current licensure/certification of the contracted provider, and accounting records documenting payment to the contractor. The school district must also maintain all documentation required to bill for SHARS services, including all documentation requirements for services provided by contracted employees. Contracted providers must maintain records in accordance with the records retention guidelines provided in the response to B1.

See also Billing Guidelines on the TEA website (refer to the billing guidelines section), and the current TMPPM section on SHARS and on Provider Enrollment and Responsibilities.

B6. What information must be included in session notes?

  • Date of service
  • Student’s Medicaid number
  • Specify whether service is provided in a group or individual setting
  • Time the session begins (billable start time)
  • Time the session ends (billable stop time)
  • Total billable minutes
  • Notation as to the activity performed
  • Student observation
  • Reference to IEP objective
  • Reference to medical necessity related to IEP objective

Example: 10/21/04, 555555555, Group, 9:00-9:30, 30 minutes, articulation (s-sound), student actively engaged, IEP objective 1.6.c

See also Billing Guidelines on the TEA website (refer to the billing guidelines section), and the current TMPPM section on SHARS.

B7. Which services require session notes?

Audiology therapy, counseling services, psychological services, occupational therapy (procedure codes 97530 and 97150), physical therapy (procedure codes 97110 and 97150), and speech therapy (procedure codes 92507 and 92508). Session notes are a good resource for the history of treatment and continuity of care. HHSC RAD recommends that districts maintain all session notes for allowable SHARS services delivered.

For more information, refer to the TEA Billing Guidelines (http://tea.texas.gov/SHARSbilling.pdf) and the SHARS section of the current Texas Medicaid Providers Procedure Manual (TMPPM) at http://www.tmhp.com/Pages/Medicaid/Medicaid_Publications_Provider_manual.asp x. 

B8. What documentation is required for assessments and related service evaluations?

Documentation for assessments (i.e., services billable under procedure code 96101) must include:

  • billable start time
  • billable stop time
  • total billable minutes
  • notation as to activity performed during session (i.e., direct testing, interpretation/report writing)

Documentation for related services evaluation (PT, OT, Speech, Audiology) must include:

  • billable start time
  • billable stop time
  • total billable minutes
  • notation as to activity performed during session (i.e., direct testing)

Also, refer to the Billing Guidelines on our website and the current TMPPM section on SHARS.

B9. Which services require a “service log” instead of session notes?

Nursing services, physician services, and personal care services require a log with the following information:

  • billable start time
  • billable stop time
  • total billable minutes
  • notation as to activity performed during session (i.e., medication administration, tube feeding, toileting, etc.)

See also Billing Guidelines on the TEA website (refer to the billing guidelines section), and the current TMPPM section on SHARS.

B10. Can an electronic signature or signature protected be used to meet the signature requirements for session notes and service logs documents? If so, what are the signature requirements for session notes and service logs documents?

For Medicaid purposes, a school district’s use of electronic records and signatures for SHARS is permissible. As long as the records are accessible to an investigator or auditor and can be reviewed as needed, maintaining the records in electronic format is acceptable from the perspective of documentation adequacy or other audit issues related to Medicaid. Each school district should determine at its own risk what standards are consistent with state and federal electronic requirements.

Electronic Signatures

  • SHARS providers must recognize the potential for misuse or abuse
  • SHARS providers must apply relevant administrative procedures, standards, and law
  • SHARS providers must ensure system and software products are protected
  • The individual whose name is on the alternate signature method and the provider bears the responsibility for the authenticity of the information attested to in the record
  • SHARS providers must check with their respective legal counsel regarding alternative signature methods and associated legal concerns

The Texas Education Agency (TEA) advises that it has no additional requirements regarding the submission of electronic data or the use of electronic signatures. The requirement that records are accessible and can be made available to an auditor or a reviewer as needed is, per TEA, sufficient for its purposes.

B11. What type of documentation is required for billing specialized transportation services?

Another billable SHARS service must be provided that same day the specialized transportation service is provided. A transportation log must be maintained recording one-way trips. IEP documentation must support the medical necessity as to why the student requires the specialized transportation adaptation. In other words, just because a student rides a vehicle that has a wheelchair lift (i.e., a specialized transportation adaptation) does not result in the school district being able to bill for specialized transportation services for that student unless the student's IEP documents the student's need for that wheelchair lift.

B12. If a provider delivers a service to a Medicaid eligible special education student, is he/she required to complete the SHARS documentation for claims submissions? 

Yes, if the provider is delivering specialized services and the services are to a Medicaid client, the provider should meet the qualifications listed in the Texas Medicaid Providers Procedures Manual (TMPPM) for the service being delivered and abide by the policy guidelines regarding proper documentation for that particular service.

Note: If there are multiple providers delivering a service in a group setting, each provider does not have to provide documentation for each child. Only one provider needs to record the necessary information required for the type of service being delivered to the students.