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    OpenPayerPolicy UpdatesPediatrics/NeonatologyEOHHS PASS policy update: Prior Auth & Limits | Op…
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    ModifiedExecutive Office of Health and Human ServicesPolicy N/A

    Personal Assistance Services and Supports (PASS) practice standards

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    Requirements and practice standards for providers delivering Personal Assistance Services and Supports (PASS) to Medicaid-eligible children and adolescents in Rhode Island, including eligibility, prior approval, clinical criteria, service planning, and provider responsibilities.

    Policy Summary
    PayerExecutive Office of Health and Human Services
    PolicyPersonal Assistance Services and Supports (PASS) practice standards
    Policy CodePolicy N/A
    Change TypeModified — operational and clinical updates
    Effective DateJul 1, 2016
    Last ReviewFeb 1, 2004
    Next Review DateN/A
    Key ActionSubmit prior authorization for PASS services (children under 6 require EOHHS/third‑party authorization 30 days before initiation).
    SourceLink
    POLICY UPDATE CHANGES

    PASS Agency responsibility to assess current clinical needs of the child and family to determine treatment intensity.

    PASS requests for children younger than 6 require EOHHS/third party payer authorization 30 days prior to initiation or continuation.

    Maximum of 6 PASS hours per day unless otherwise clinically justified.

    PASS Service Plans are approved for 12 months with required 6 month progress reports.

    Clinical Consultation (T1027) frequency increased to 2 hours monthly with potential for additional hours case-by-case.

    PASS treatment hours per week must be substantiated with medical necessity and measurable goals: up to 20 hours for PASS alone; up to 25 hours combined with HBTS when documented.

    6max PASS per day
    12 moService Plan duration
    2 hrs/moClinical consultation min
    20Max PASS hrs/week
    25Max PASS+HBTS/week

    Coverage Criteria and Clinical Eligibility

    Initial Service Plan Approval

    Covered when ALL of the following are met

    Federal and program eligibility: Recipient is Medicaid-eligible (birth to 21) and meets the Federal definition of disability; eligible through SSI, Katie Beckett, Adoption Subsidy, Rite Care, or Rite Share; child lives at home with consenting legal guardian or is over 18 and consents to services.

    See eligibility requirements.

    Clinical Eligibility

    AND the following clinical conditions must be documented

    Clinical documentation: A formal behavioral health or medical diagnosis by a qualified licensed health care professional within the past 3 years, including at minimum a clinical diagnostic interview and evidence of functional impairment; neuropsychological/psychological/educational testing and/or language evaluation when indicated; and family/caregiver willingness to accept and cooperate with PASS as specified in the Service Plan.

    Provider agencies shall work with families and third-party payers to obtain necessary evaluations.

    Policy Summary
    PayerExecutive Office of Health and Human Services
    PolicyPersonal Assistance Services and Supports (PASS) practice standards
    Policy CodePolicy N/A
    Change TypeModified — operational and clinical updates
    Effective DateJul 1, 2016
    Last ReviewFeb 1, 2004
    Next Review DateN/A
    Key ActionSubmit prior authorization for PASS services (children under 6 require EOHHS/third‑party authorization 30 days before initiation).
    SourceLink
    On This Page
    Coverage Criteria and Clinical EligibilityService Codes, Units, and Billing RulesProvider Responsibilities, Authorizations, and Operational RulesDefinitions and Service ComponentsPolicy Background and ScopePolicy Changes and Effective Dates

    Continuing Care / Reauthorization

    Reauthorization requires ALL of the following

    Continuing care: Condition severity and resulting impairment continue to require a PASS Service Plan to maintain and/or improve adaptive and functional skills with clinical information demonstrating disability and functional impairment using a standardized assessment tool (e.g., Vineland); progress toward goals is clearly evident, measurable and described in observable terms; and the family is adhering to requirements set forth in the PASS treatment plan.

    Service Plan renewal includes reassessment of progress and necessary revisions.

    Continuing Care / Reauthorization

    Service Plan continuation/reauthorization requires ALL of the following:

    Continuing care criteria: 1. Severity of condition(s) and resulting impairment continue to require a PASS Service Plan to maintain and/or improve adaptive and functional skills, with clinical information demonstrating disability and functional impairment using a standardized assessment tool (e.g., Vineland). 2. Progress in relation to goals is clearly evident, measurable and described in observable terms. 3. The family is adhering to requirements set forth in the PASS treatment plan.

    No retroactive approvals; parents/families must participate and sign renewals.

    Assessment and Service Plan Development

    Assessment and Service Plan must meet ALL of the following:

    Assessment and Service Plan Development: Assessment and Service Plan development must be completed under the supervision of a qualified RI-licensed health care professional; the PASS Agency coordinator must assess family readiness and work with the family to design the Service Plan; a minimum of one home visit to assess health and safety must occur prior to submission/authorization; the PASS Agency Clinical Consultant must assist in writing, review and sign the Service Plan; Service Plans are authorized for 12 months and renewable annually; back-up plans for Direct Service Worker absence must be included.

    Service Plan renewal requires reassessment of progress toward goals and agreement of all parties.

    Treatment Intensity (Hours per Week)

    Treatment intensity (hours/week) covered when ALL of the following are documented:

    Treatment Intensity Factors: PASS treatment hours per week must be substantiated by documented medical necessity and measurable goals specifying frequency and duration of each service; determination must consider child's age; ability to engage in sustained treatment; type, nature, and course of condition; severity of behaviors; other treatment/educational services received; impact on family functioning; co-existing conditions; biological/neurological abnormalities; current functional capacities; family factors; and interaction with other agencies or providers.<= 20 hours/week

    PASS Agency is responsible for determining appropriate intensity up to 20 hours/week; combined PASS+HBTS up to 25 hours when documented.

    PASS coverage and medical necessity

    Covered when services meet medical necessity and program intent

    PASS coverage conditions: Services support at least one core PASS domain (activities of daily living, making self-preserving decisions, or participation in social/community settings) and are intended to enhance independence, social integration, and facilitate transition when applicable; PASS is designed to complement existing therapeutic services or serve as a step-down/alternative when indicated, not to replace licensed mental health, nursing, school-based, or respite services.

    PASS will not be used for respite/childcare or to substitute for licensed clinician services or private duty nursing.

    Medical necessity determination: A physician or other medical service provider's prescription or recommendation is required for determination of medical necessity, but the Medical Assistance Program makes the final determination; services must be provided in the most cost-effective, efficient and appropriate manner and not solely for convenience.

    See Appendix 1 definition of Medical Necessity.

    PASS eligibility and intake

    Covered when ALL of the following are met:

    PASS eligibility preconditions: 1) Child is Medicaid-enrolled and referred; 2) Stability of the child's condition is evaluated and acceptable; 3) Home environment safety is evaluated and acceptable; 4) Family is willing and capable of assuming the risks and responsibilities of consumer-directed care; agencies must document determinations and provide alternative recommendations for ineligible families.

    Intake protocols must address referrals, information provision, eligibility/admission criteria, alternatives, confidentiality, and HIPAA compliance.

    Staff qualifications and training for service provision

    Covered when ALL of the following staffing and training requirements are met:

    Staffing qualifications and training: 1) PASS Agency Coordinator: minimum high school diploma or equivalent plus 2 years college in human services or related field, demonstrated competency with families of children with special health care needs, and minimum one year experience with a similar population; 2) Clinical Consultant: licensed RI health care professional (LICSW, LCSW, RN with Master's, Psychologist, PT, OT, SLP, LMHC, LMFT, BCBA) with minimum two years' relevant experience; 3) Direct Service Worker: at least 18 years old, high-school diploma or equivalent, competent in child-specific tasks, not residing in the child's household; 4) All staff must receive agency orientation and role-specific training with personnel files documenting completed orientation; 5) Agency and child-specific training for Direct Service Workers (including CPR/First Aid for children/young adults, client rights, reporting, payroll/tax) must be completed prior to initiation of Direct Services and documented with family sign-off on Job Description/Contractual Agreement.

    Agency must maintain written training plans and annual training schedules; Direct Services begin after Assessment/Service Plan completion and prior authorization approval.

    PASS Eligibility Criteria

    Applications must include intake protocols that determine eligibility and admission using ALL of the following evaluations:

    PASS eligibility core criteria: a. Stability of the child's condition; b. Safety of the home environment; c. Family willingness to assume the risks and responsibilities of consumer-directed care; agencies must provide alternative recommendations for families not eligible.

    Intake protocols must also address referrals, information provision, confidentiality, and HIPAA compliance.

    Timeliness Standards for New Referrals

    PASS Agencies must meet ALL of the following timeliness standards for new referrals:

    Timeliness standards: 1) Offer first meeting within 14 calendar days of referral; 2) Complete assessment and Service Plan within 30 calendar days of the first meeting; 3) Initiate direct services within 30 calendar days of signing the Service Plan; 4) Complete reauthorization for all Service Plans requiring renewal at least 15 calendar days prior to plan expiration.

    Failure to meet these standards is noncompliant with Practice Standards.

    Operational and approval criteria

    PASS Agencies must meet the following performance and approval criteria:

    Timeliness for new referrals: 1) Offer first meeting within 14 calendar days of referral; 2) Complete assessment and Service Plan within 30 calendar days of the first meeting; 3) Initiate direct services within 30 calendar days of signing the Service Plan; 4) Complete 100% of Service Plans requiring renewal at least 15 calendar days prior to expiration.as stated

    From Timeliness Standards for New Referrals.

    Provider application and approval: Applicants are evaluated on written materials; review process may take a minimum of two months and include on-site inspections; favorable determination results in a Letter of Approval; initial period of approval lasts 3 years from issuance.as stated

    See Submission of Application and Period of Approval.

    EOHHS enforcement actions: EOHHS may inspect records and sites, require corrective action, suspend new referrals up to 6 months, require recoupment of funds, institute Provisional Approval after 121 days of continued non-compliance (triggering 90 days of intensified oversight), and may revoke approval for inability to cure deficiencies or violations.as stated

    Consequences and oversight measures described in EOHHS Oversight and Authorization.

    PASS is not intended for children who present with marked impairments in self-control (for example, significant aggression or conduct problems), severe disturbances in thinking, perception, or mood, or learning disabilities. PASS is designed to strengthen functioning and support development in the least restrictive setting and is explicitly not intended to replace school-based services, behavioral health treatment delivered by licensed clinicians, certified nursing services, or RESPITE. The Medical Assistance Program remains the final arbiter of medical necessity; services recommended for convenience of the beneficiary or provider are not considered medically necessary.

    Direct Service Workers provide one-to-one personal assistance under the direction of the parent/caregiver and may not administer medication. Medication administration is governed by the RI Nurse Practice Act and cannot be assigned to unlicensed personnel, which includes Direct Service Workers. If a child requires medication during service delivery, the family must arrange for another adult or licensed clinician to administer it.

    PASS will not be used for respite or routine childcare and is not a substitute for mental health services provided by licensed clinicians. PASS also must not replace services provided by Private Duty Nursing or duties assigned to Certified Nursing Assistants; where both PASS and nursing are required, they should not be provided concurrently to perform the same services.

    Medicaid does not reimburse treatments that are experimental or investigational. Services or interventions that are not generally recognized as accepted medical practice are excluded from PASS coverage.

    PASS Agencies may decline to write a Service Plan when the agency determines PASS is not suitable due to health or safety concerns, when the family is unwilling or incapable of assuming the risks and responsibilities of consumer-directed care, or when a clinician has assessed and documented that the child does not require the level of care provided by PASS. The agency must document specific reasons for declining and retain that documentation.

    When an applicant/family is found not eligible for PASS, the PASS Agency must provide alternative recommendations and information about other appropriate services or resources. Intake protocols must include procedures for offering alternatives to families who do not meet PASS admission criteria.

    EOHHS reserves the authority to exclude any item or service it determines is not medically necessary, is unsafe, is experimental/investigational, or is not generally recognized as an accepted medical practice. This authority may be used to limit the amount, duration, or scope of services provided under PASS.

    Services provided solely for the convenience of the beneficiary or provider are not considered medically necessary and therefore are not reimbursable under PASS. The Medical Assistance Program makes the final determination of medical necessity; a provider’s prescription or recommendation does not guarantee a determination of medical necessity.

    Services may be suspended or terminated when the child, family, or guardian fails to comply with PASS Agency program rules despite multiple documented attempts to engage them. PASS Agencies must notify families in writing of any suspension or termination and families have the right to appeal the decision to EOHHS.

    EOHHS does not reimburse experimental or investigational treatments and will not cover services provided solely for convenience. These exclusions reinforce that PASS must be medically necessary, safe, and consistent with generally accepted medical practice.

    A clinician’s documented assessment that the child does not require the level of care provided by PASS is a valid basis for declining to offer or continuing PASS services. PASS Agencies must record and retain the clinician’s assessment and the rationale for service decisions.

    Items or services that are not medically necessary, considered unsafe, experimental, or not generally recognized as accepted medical practice may be excluded from PASS coverage by EOHHS. Additionally, PASS will not be used to provide services that should be delivered by licensed mental health clinicians, nursing staff, or other regulated providers.

    Service Codes, Units, and Billing Rules

    Referenced HCPCS/T codes in PASS practice standardsHCPCS
    T1027Clinical Consultation (2 hours monthly minimum)
    T1013U1Interpretation code for PASS clinical consultations (may be used up to 2 hours monthly)
    H2016Direct Implementation (billing contingent on identification of Direct Service Worker)
    Covered PASS service codesHCPCSCovered
    T1023-U1Assessment and Service Plan Development
    T1019Direct service reimbursement (three rates by worker education/experience)
    H2016Direct Implementation
    T1027Clinical Consultation
    T1013U1Interpretation
    Clinical consultation and weekly treatment hours
    Clinical consultation frequencyClinical consultation (T1027): 2 hours per month
    Maximum PASS weekly hoursUp to 20 hours per week (must be substantiated with medical necessity and measurable goals)
    Maximum combined PASS+HBTS weekly hoursUp to 25 hours per week when PASS is combined with HBTS (must be documented and justified)
    Session length and consultation limits
    Billing unitUnit = 15 minutes per session for Direct Services
    Consultation/Interpretation monthly limitClinical Consultation (T1027) and Interpretation (T1013U1): up to 2 hours per month
    Unitization for claimsAll claims must be submitted within 12 months of date of service and reflect 15-minute units

    Provider Responsibilities, Authorizations, and Operational Rules

    Prior Authorization

    Obtain prior authorization; weekly batch submissions for FFS

    PASS requires prior approval for Medicaid-eligible clients. For fee-for-service families, prior authorizations using a batch form must be sent once a week to EOHHS prior to the start date of service; managed care enrollees follow third‑party payer procedures. Provider agencies must obtain referral information to screen and determine clinical eligibility before requesting prior authorization.

    • Batch prior authorizations: submit once weekly to EOHHS for FFS families, prior to service start date.
    • Follow managed care payer procedures for MCO-enrolled members.
    • Conduct initial screening and clinical eligibility determination before requesting authorization.
    Prior Authorization

    30‑day prior authorization required for children under age 6

    Any PASS request for a child younger than six years requires authorization from EOHHS or the third‑party payer at least 30 days prior to initiation or continuation of services.

    • Do not start or continue PASS for children <6 without EOHHS/third‑party payer approval obtained ≥30 days in advance.
    Billing Rule

    Authorize specific PASS procedure codes before billing

    Designated procedure codes for PASS service components must be authorized before billing. Assessment/Service Plan Development and specified PASS components use HCPCS/T codes (examples include T1023‑U1, T1019, H2016, T1027, and T1013U1) and units/hours vary by code.

    • T1023‑U1 for Assessment and Service Plan Development must be authorized.
    • Direct service codes (e.g., T1019), Direct Implementation (H2016), Clinical Consultation (T1027) and Interpretation (T1013U1) require authorization and follow the policy's units/limits.
    Prior Authorization

    Document provider prescription/recommendation for medical necessity

    A physician or other medical service provider must prescribe or recommend services to support a medical necessity determination; however, the Medical Assistance Program makes the final determination of medical necessity.

    • Obtain and include the prescribing/recommending clinician's documentation when requesting authorization; EOHHS makes the final medical necessity decision.
    Prior Authorization

    Complete agency and child‑specific training before Direct Services start

    Agency and child‑specific training for Direct Service Workers must be completed prior to initiation of Direct Services; family sign‑off on the Job Description/Contractual Agreement documents readiness and competency. After Assessment/Service Plan completion and prior authorization approval, Direct Services may begin and agencies may bill for Service Plan Implementation.

    • Provide agency orientation and role‑specific training; document in personnel files.
    • Complete child‑specific training and obtain family certification of worker readiness before starting services.
    • Begin billing for Service Plan Implementation only after Assessment/Service Plan completion and approved prior authorization.
    Prior Authorization

    Ensure Service Plan approval and meet timeliness milestones

    Service Plans must be completed, approved, and time‑bound: offer first meeting within 14 days, complete assessment and Service Plan within 30 days of that meeting, and initiate direct services within 30 days of signing the Service Plan. Reauthorizations must be completed at least 15 days prior to plan expiration. Administrative hearings can alter prior authorization.

    • First meeting: within 14 calendar days of referral.
    • Assessment and Service Plan: complete within 30 calendar days of first meeting.
    • Initiate services: within 30 calendar days of signing the Service Plan.
    • Reauthorization: complete ≥15 days prior to plan expiration.
    • Be aware that Administrative Fair Hearing outcomes may adjust prior authorization.
    Note

    Meet 30‑day timelines for assessment, plan completion, and service start

    Complete an assessment and Service Plan within 30 calendar days of the first meeting and initiate direct services within 30 calendar days of signing the Service Plan.

    • Track and document dates to demonstrate compliance with 30‑day assessment/plan and 30‑day service initiation requirements.
    Note

    Anticipate ≈2 months for provider application review (may include site visit)

    Provider applicants should expect a minimum two‑month review period for approval; reviews may include on‑site inspections and requests for additional clarification before issuing a Letter of Approval.

    • Prepare required written materials and be available for possible site inspections and follow‑up requests during the ~2‑month review.
    Note

    Perform intake screening, document eligibility, and support orderly transfers

    Conduct initial screening and determine clinical eligibility before enrollment; families may choose a PASS Agency or use their HBTS/PASS Agency. When transferring, the current PASS Agency must assist in an orderly transfer with coordination and written documentation.

    • Document intake screening results and eligibility determination.
    • Maintain written coordination records when assisting family transfers between agencies.
    Step Therapy

    Substantiate and document treatment intensity (hours/week)

    Treatment intensity (direct service hours/week) must be justified by documented medical necessity and measurable goals; PASS Agencies determine appropriate intensity up to 20 hours/week (up to 25 hours/week when combined with HBTS and documented).

    • Support requested hours with measurable goals, frequency/duration, and multidisciplinary collaboration.
    • Maximums: up to 20 hours/week for PASS alone; up to 25 hours/week combined with HBTS when documented.
    Note

    Screen for eligibility, home safety, and family readiness at intake

    Before initiating services, intake protocols must assess stability of the child's condition, home safety, and the family's willingness and capacity to assume consumer‑directed responsibilities; applicants must provide alternative recommendations when families are not eligible.

    • Document assessments of condition stability, home safety, and family readiness in the intake record.
    • Provide and record alternative recommendations if PASS is not appropriate.
    Note

    Document eligibility determinations and offer alternatives when ineligible

    Intake must determine eligibility and admission criteria (stability, home safety, family willingness) and, if not eligible, provide alternative recommendations to families.

    • Maintain written intake protocols and document determinations and alternatives offered.
    Note

    Comply with EOHHS program modifications and service limits

    EOHHS may amend program requirements with reasonable notice and may limit amount, duration, and scope of services when not medically necessary or unsafe; providers must comply with any such modifications.

    • Monitor EOHHS notices for program changes and update agency policies and Service Plans accordingly.
    Documentation Required

    Submit recent formal diagnosis and measurable goals for Service Plan approval

    Service Plan approval requires documentation of a formal behavioral health or medical diagnosis made within the prior three years by a qualified licensed provider, demonstration of disability with functional impairment, and that goals are measurable with documented progress.

    • Include a formal diagnosis (≤3 years), standardized assessments as needed, and measurable goals in the Service Plan submission.
    Documentation Required

    Provide standardized assessments and reassessments for reauthorization

    Clinical documentation for reauthorization must demonstrate ongoing disability with functional impairment using a standardized tool (e.g., Vineland), document progress toward goals, and include the Clinical Consultant's reassessment and summary at plan conclusion.

    • Provide standardized assessment results (such as Vineland) and measurable progress data at renewal.
    • Clinical Consultant must document and summarize the child's and family's response over the 12‑month Service Plan period.
    Denial Risk

    Provide written notification and inform families of appeal rights for suspensions/terminations

    The PASS Agency must notify the family in writing of all instances or circumstances that affect temporary suspension or termination of services; families have the right to appeal to EOHHS.

    • Provide written notice to families for suspensions/terminations and inform them of appeal rights.
    Documentation Required

    Maintain orientation, training, and client records to substantiate billing

    Personnel files must document completed agency orientation and training; client records must substantiate all billed services and include assessment, Service Plan goals, documentation of services and status changes, and informed consent where required.

    • Keep orientation/training records in staff personnel files.
    • Ensure client records support every billed unit and contain required assessment, plan, progress, and consent documentation.
    Documentation Required

    Include written policies/procedures for intake, assessment, and documentation in applications

    Applications for approval must include written policies and procedures addressing intake, assessment and Service Plan development, documentation procedures for clinical consultation, and Service Plan modification processes.

    • Submit documented policies/procedures for assessment, plan development, clinical consultation, and recordkeeping with the application.
    Documentation Required

    Provide family information, grievance processes, and obtain signed consent/acknowledgment

    Provide informational materials and grievance/appeal processes to families at onset and annually; the Service Plan must include a signed family statement affirming understanding of rights and responsibilities, and families may terminate or suspend PASS as desired.

    • Give families written materials on PASS services, grievance/appeal processes, and obtain signed acknowledgment of understanding.
    • Re‑provide materials annually and document family signatures.
    Billing Rule

    Record weekly direct service hours and obtain co‑signed timesheets to support billing

    Record and submit systematic weekly documentation of PASS direct service hours; Direct Service Worker timesheets must be co‑signed weekly by the designated family supervisor. Services billed must correspond to approved Service Plan hours and be supported by written documentation.

    • Maintain weekly co‑signed timesheets and supporting documentation that match billed units.
    • Ensure claims are within the Service Plan's approved hours.
    Note

    Conduct parent satisfaction surveys at plan completion and report annually

    Parent satisfaction surveys must be conducted at the completion of each authorized Service Plan and reported to EOHHS annually (reported to EOHHS by April 1); surveys should include quantitative and qualitative feedback on family‑centeredness, clinical consultation availability, progress, communication, and staff performance.

    • Conduct surveys at plan completion; analyze results and submit annual report to EOHHS by April 1.
    • Include measures of family centeredness, clinical consultation utilization, progress, communication, and staff availability.
    Denial Risk

    Verify Medicaid coverage; risk of nonpayment and retroactive reimbursement conditions

    Verify continuous Medicaid coverage before providing services; loss of Medicaid eligibility may result in nonpayment. Providers may request retroactive reimbursement once coverage has resumed only if there has been no lapse in Medicaid coverage and the child has an approved PASS Service Plan.

    • Confirm enrollment via the RI provider portal and document verification in the record.
    • If coverage issues arise, follow retroactive reimbursement rules: no lapse in coverage and an approved PASS Service Plan are required.
    Denial Risk

    Non‑participation in renewal, loss of eligibility, or higher‑level care may trigger suspension

    Failure of a family to participate in the renewal process, loss of Medicaid eligibility, or admission to a residential program/hospital can result in suspension of services; agencies must document attempts to engage the family.

    • Document family outreach and renewal attempts; lack of participation can trigger suspension.
    • Record changes in eligibility or higher‑level care admissions and act per discontinuation procedures.
    Denial Risk

    Recognize and document triggers that justify suspension or termination of services

    Services may be suspended or terminated for loss of Medicaid eligibility; risk of harm to self/others or need for a more intensive level of care; safety risks in the home to staff (threats, substance use, firearms, contagious illness); failure to follow agency program rules despite documented attempts; or admission to a residential program or hospital.

    • Provide written notice to families for suspension/termination and document the specific trigger and supporting evidence.
    Note

    Document reasons when declining to write a Service Plan; repeated refusal risks agency review

    PASS Agencies may decline to write a Service Plan when PASS is unsuitable due to health/safety concerns, family unwillingness/incapacity, or clinician documentation that the child does not require PASS level of care; document reasons for declining and note that consistent refusal to accept referrals may prompt a comprehensive review of the agency's approval status.

    • Maintain documentation of reasons for declining and be aware that repeated refusal of referrals can trigger agency review.
    Note

    Inform families of administrative fair hearing rights; hearing can change prior authorization

    If a family objects to an EOHHS decision about authorization of a Service Plan, they may request an administrative fair hearing; the hearing decision can adjust prior authorization necessary for claims to pay.

    • Advise families of fair hearing rights and be prepared to adjust authorizations/claims based on hearing outcomes.
    Denial Risk

    Prepare for EOHHS inspections and potential sanctions; noncompliance risks provisional approval and revocation

    EOHHS may inspect records and sites, require corrective action, suspend new referrals up to six months, require recoupment of funds, institute Provisional Approval after 121 days of continued non‑compliance (leading to 90 days of heightened oversight), and may revoke approval for failure to cure deficiencies or violations of Medicaid/state laws.

    • Maintain readiness for record/site inspections and comply promptly with corrective action plans.
    • Understand provisional approval and remediation timelines to avoid revocation and financial sanctions.
    Note
    Note

    Definitions and Service Components

    PASS — Personal Assistance Services and Supports
    DefinitionPersonal Assistance Services and Supports (PASS): assistant services enabling children/adolescents with special health care needs to accomplish tasks they would normally perform if not disabled; funded under EPSDT for Medicaid under age 21.
    Purpose domainsSupports activities of daily living (ADLs/IADLs), self‑preserving decision‑making, and participation in social/community settings.
    Service modelConsumer‑directed model where families participate in planning, manage and supervise Direct Service Workers to meet Service Plan goals.
    Federal definition of disability (for PASS eligibility)
    Federal disability definitionA child must have a physical or mental condition (or combination) resulting in marked and severe functional limitations expected to last at least 12 months or result in death.
    Program eligibility linkParticipants must also meet EOHHS medical necessity definition to be eligible for PASS.
    Medicaid populationPASS serves Medicaid‑eligible children from birth to their 21st birthday who meet the Federal definition of disability.
    Direct Services and Direct Service Worker role
    DefinitionDirect Services: one‑to‑one personal assistance provided by a Direct Service Worker under the direction of the parent/caregiver in accordance with an individualized approved Service Plan; units are 15 minutes.
    Role of Direct Service WorkerPerforms Service Plan activities to support quality and continuity of care, aids family in implementation, and is supervised by designated family supervisor(s).
    Medication limitationDirect Service Workers cannot administer medication; medication administration cannot be assigned to unlicensed personnel.
    Clinical Consultation — definition and activities
    DefinitionClinical Consultation: services by licensed clinical staff to provide support and assessment, enhance family skills, train/supervise Direct Service Workers, and review goals and progress at least bimonthly.
    Settings and activitiesMay occur in agency, home, community, or by phone; includes observation of progress, appraisal of worker performance, and recommendations for approaches and techniques.
    Documentation roleClinical Consultant assists in writing, reviewing and approving Service Plans and must document and summarize child/family response at conclusion of the 12‑month Service Plan.
    PASS — ADLs / IADLs emphasis
    PASS intentPASS is intended to support ADLs/IADLs, self‑preserving decision‑making, and community participation, enhancing independence and social integration.
    Complementary rolePASS shall complement existing therapeutic services or serve as a step‑down/alternative to other clinical care when indicated.
    Not a substitutePASS is not intended to replace school‑based services, licensed mental health treatment, or Private Duty Nursing/CNA services.
    Medical Necessity — definition used for determinations
    Medical necessity definitionMedical Necessity: services required for prevention, diagnosis, cure, or treatment of a health‑related condition, including services necessary to prevent regression; must be provided cost‑effectively and not solely for convenience.
    Decision authorityA physician or other medical service provider's prescription/recommendation is required for determination, but the Medical Assistance Program makes the final determination of medical necessity.
    Application to PASSPASS services must meet the Medical Necessity definition to be covered and authorized.
    PASS service components — core elements
    Component 1: Assessment & Service Plan DevelopmentComprehensive assessment and development of an individualized Service Plan supervised by qualified clinical staff; includes home visit(s) and documentation for authorization.
    Component 2: Direct ServicesOne‑to‑one implementation of the Service Plan by Direct Service Workers using 15‑minute units to achieve measurable goals.
    Component 3: Service Plan ImplementationOngoing collaboration and technical assistance from PASS Agency to family to support training, supervision, and payroll/administrative functions.
    Component 4: Clinical ConsultationLicensed clinical staff provide regular consultation to review goals, train/supervise workers, and document progress toward Service Plan renewal.
    Direct Service Worker — minimum qualifications
    Minimum ageDirect Service Worker must be at least 18 years of age.
    EducationMust have a high‑school diploma or equivalent.
    Competency and exclusionsMust demonstrate competency to work with children with special health care needs, ability to carry out Service Plan tasks, have no legal obligation to support the child, and not live in the child's household.
    PASS Direct Services — scope and goals
    ScopePASS Direct Services provide supports to enhance the child's ability to perform ADLs/IADLs, make self‑preserving decisions, and participate in social roles and settings in the least restrictive environment.
    GoalsServices aim to improve adaptive and functional skills, independence, social integration, and quality of life indicators within PASS domains.
    ImplementationDirect Services are delivered per the Service Plan with agency oversight, family supervision, and documentation of child's response to interventions.
    Consumer‑directed care — family participation model
    ModelConsumer‑directed care: families actively participate in planning, management, oversight of the Service Plan, and supervise Direct Service Workers.
    Family responsibilitiesFamilies assume risks/responsibilities (e.g., selecting/supervising workers, maintaining safe home environment) and must sign service agreements and job descriptions.
    Agency rolePASS Agencies provide training, technical assistance, payroll and administrative support to enable families to manage consumer‑directed services.
    Clinical Consultation — acceptable provider types
    Acceptable provider typesClinical Consultation must be rendered by licensed clinical staff (e.g., LICSW, licensed mental health clinician, LMFT, licensed OT/PT, licensed psychologist, licensed speech and language therapist) holding valid Rhode Island licenses.
    Therapist inclusionOccupational Therapists, Physical Therapists, and Speech and Language Therapists may be included as part of the clinical team and may bill for Clinical Consultation.
    Interpreter roleInterpretation (T1013U1) may be used for Clinical Consultations if necessary, up to 2 hours monthly, with certified interpreters experienced with children with special health care needs.

    Policy Background and Scope

    Background: PASS is a Medicaid-funded, consumer-directed program that provides one-to-one personal assistance to children and adolescents with special health care needs to support activities of daily living, development, and community participation. The program’s intent is to strengthen functioning, promote inclusion, and empower families to direct care. PASS is intended to complement—not replace—school services, licensed behavioral health treatment, nursing care, or respite; it emphasizes family participation, measurable goals, and services delivered in the least restrictive setting.

    Policy Changes and Effective Dates

    2016-07-01Effective dateLatest

    Practice standards updated with clarified agency assessment responsibility for treatment intensity, daily hour limits, and authorization rules for children under 6; Service Plans authorized for 12 months with 6-month progress reports.

    Operational change

    Clinical Consultation (T1027) frequency increased to 2 hours monthly (from 2 hours every 2 months), with additional hours determined case-by-case; interpretation code (T1013U1) may be used up to 2 hours monthly.

    Operational change

    PASS treatment intensity ceilings established: up to 20 hours/week for PASS alone and up to 25 hours/week combined with HBTS when documented with medical necessity and measurable goals.

    Operational change

    Maximum of 6 PASS hours per day unless otherwise clinically justified.

    Operational change

    Prior authorization process revised: PASS requests for children younger than 6 require EOHHS/third-party payer authorization 30 days prior; batch prior authorizations should be sent once weekly for fee-for-service families.