"Authorization" - Prior approval required before any service can be rendered. The exception to this rule is the initial IFSP meeting. IFSP Meeting authorizations will be based upon actual attendance at the IFSP meeting. For direct services, authorizations are generated as either Individual or Group.
Individual Authorization - An authorization to provide services to a single child/family based upon a frequency, intensity and duration. An Individual Authorization cannot be used to provide services to a child/family during the same time frame that the child/family is receiving authorized group therapy services.
Group Authorization - An authorization to provide direct services to two or more children during the same period of time based upon a frequency, intensity and duration. One provider can serve up to four (4) children or multiple families (parent groups) during a group session. See service description "Family Training and Support" for information on groups and Interpreters.
Evaluation/Assessment Authorization - An authorization to provide evaluation or assessment to determine a child's initial eligibility, re-determination of eligibility, the need to add new types of services to an existing IFSP, and if deemed necessary, for the annual six month review.
IFSP Meeting Authorization - An authorization that is based on attendance of the IFSP meeting. This is the only authorization that is generated after the service has been provided. The amount of time allowed for billing on this authorization will be the amount of time that the provider was actually in attendance at the IFSP meeting, whether by phone or in person.
Onsite Authorization - A site where the provider of services is located during the work day that the family must travel to in order for their child to receive services. This would include agencies, hospitals, satellite sites and other similar settings. This type of setting may not be considered a natural environment.
Offsite Authorization - A site where the child typically spends his or her day which may be the child's home, daycare center or other setting. The provider travels to the child to provide services. This is considered a natural environment.
Offsite authorizations would also include settings where both the child and provider must travel to the site of service. This type of setting would include sites such as a community swimming pool, a park or other community setting that is frequented by typically developing children.
"Child Outcomes" The changes experienced as a result of the Early Intervention services and supports provided to a child. All children in Early Intervention will have their skills compared to other children their age in three areas: positive social-emotional skills (including social relationships), acquisition and use of knowledge and skills, and taking appropriate action to meet needs. These three areas, having relationships with family and friends, being able to gain new information and skills, and being able to communicate and meet needs, are believed to be important for all young children. A child's status in the three child outcome areas is determined when the child enters the Early Intervention Services System, at his/her annual IFSP meeting, and again shortly before exiting the system. Child outcomes compares a child's status to other children of the same age.
"Concerns" What family members identify as needs, issues, or problems they want to address as part of the IFSP process.
"Co-treatment" The integration of treatment by two disciplines in order to maximize therapy benefits for one individual child/family while working towards the achievement of immediate and long term goals. If it is determined at the initial IFSP meeting that co-treatment is a need, functional outcomes must be included in the IFSP that provide a clear focus and direction for the recommended co-treatment services. The outcomes must be related to a necessary skill and should state a process and a product. Co-treatment must be based upon a child's needs and not provider logistics. Co-treatment is not considered group therapy. For more information see definition of "Group Therapy".
"DHS" Illinois Department of Human Services
"Direct Service" Treatment services provided directly to an eligible child or an eligible child's family in accordance with their Service Plan. All direct services must be justified by functional outcomes that are included in a child's IFSP. See definition of functional outcomes for more information. One person cannot provide services to the same child/family as two disciplines. Example: One person cannot provide services as a Developmental Therapist and as a Occupational Therapist.
"Documentation" You are required to maintain documentation to support each date of service and each procedure code that you bill to the CBO for a period of at least six years from the child's completion of EI services, and permit access to these records by the local CFC and DHS, or if they are Medicaid reimbursable services the Illinois Department of Healthcare and Family Services and the Centers for Medicare/Medicaid Services (CMMS), and the United States Department of Education.
If there are outstanding audit exceptions, records shall be retained until such exceptions are closed out to the satisfaction of DHS. If there is active or pending legal action, records shall be retained until a final written resolution is achieved. The Provider shall also make himself/herself available, as required, for mediation, impartial administrative proceedings or other legal proceedings.
Documentation is a chronological written account kept by you of all dates of services provided to, or on behalf of, a child and family. This includes IFSP development time and the results of all diagnostic tests and procedures administered to a child. All documentation, including the signature of the provider who creates the documentation, must be readable and understandable to families and to persons who will monitor or audit the Payee's billing to the CBO. Documentation must include:
- Physician authorization/order.
- Documentation of evaluation/assessment should include a record note that identifies the date of service that the evaluation or assessment was completed, time used to complete the evaluation or assessment, time used to write the report based upon the results of the evaluation or assessment, and a copy of the final report that was submitted to the CFC. The date of service is the date that the formal assessment tool was administered. For a six month review, if it is determined that a formal assessment is not required, providers may summarize their record notes to develop the required six month report. In this case documentation would consist of a record note stating that a report was created based upon the summary of record notes and a copy of the final report.
- Daily documentation of the services provided, including date and length of time of service billed, time in and time out for direct services, or exact time used in minutes for IFSP development. Daily documentation is written and signed by the provider who actually provided the services and consists of a complete overview of the services provided for each procedure code and date of service billed. A check list or pages from an appointment book are not considered documentation or a complete overview of the services provided. NOTE: Documentation overview and provider signature must be readable and understandable to families and to persons who will monitor or audit the Payee's billing to the CBO.
- Consultations among members of the IFSP team, including the service coordinator and eligible child's physician, can occur via secure email or fax, as long as the time used is documented with a begin/end time or exact time used in minutes. Email sent via the "public internet" is not considered secure. Printed copies of secure emails or faxes must be kept in each child's file as documentation of the consultation.
- EI does not allow a provider to round up time. So it is very important that all record notes include the exact begin/end time or exact time used in minutes for IFSP development time. In addition, all documentation must justify the amount of time actually billed to and paid by the CBO.
- Progress documentation
- Documentation of continued physician authorization
- Documentation of discharge from treatment.
- Supervision notes that document all contact between the supervisor who is responsible for a child's case and the associate level provider who is actually providing the direct service to the child. Calendar pages that identify dates of supervision are not considered supervision notes or documentation.
Transportation providers' documentation should include:
1. A travel log that documents all trips billed, including mileage, departure and destination information.
Interpreter's, Interpreters for the Deaf and Translators documentation should include:
- Daily documentation of services provided, including date of service, discipline for which you have interpreted services and time in/out. Daily documentation should be signed by the provider who actually completed the services and wrote the documentation. Calendar pages are not considered documentation.
- Type of interpretation: verbal, sign, or written translation
- If written translation, type of document translated (ex: IFSP)
- Copy of the document to translate and copy of the final document after translation. NOTE: EI does not pay for translation of non-EI documents.
In addition, providers should also keep the following:
- Copies of all authorizations under which you have billed for services.
- A copy of the child's current IFSP.
- Copies of all claims submitted to insurance and to the CBO,
- Copies of all Explanation's of Benefit received from insurance and the CBO,
- Any correspondence sent or received on behalf of the child,
PLEASE NOTE: Providers who are not enrolled with the CBO and associate level providers who are not Early Intervention credentialed, are NOT considered eligible Early Intervention providers and should NOT provide services to eligible Early Intervention children unless approved through a provisional authorization.
In the absence of proper and complete documentation, no payments will be made and payments previously made will be recouped by DHS or HFS.
One case note signed by multiple providers is considered unacceptable documentation. Each provider that provides a service to a child must maintain documentation to support the actual services provided and each date of service and each procedure code billed to the CBO. This includes providers of group therapy services.
"Eligibility Criteria" Children residing in Illinois who are under the age of three years and their families are initially eligible for Early Intervention (EI) services if written evaluation reports completed by a multidisciplinary team confirm that the child:
- Has a developmental delay; or
- Has a physical or mental condition which typically results in developmental delay; or
- Is at risk of having substantial developmental delays, according to informed clinical judgment.
"Developmental delay" means a Illinois Department of Human Services (DHS) determined eligible level of delay in one or more of the following areas of childhood development: cognitive; physical, including vision and hearing; language, speech and communication; social-emotional; or adaptive self-help skills. The eligible level of delay must have been:
- Measured by a DHS-approved diagnostic instruments and standard procedures; (see ATTACHMENT 8: APPROVED ASSESSMENT INSTRUMENTS) or
- Confirmed through informed clinical judgment of the multidisciplinary team if the child is unable to be appropriately and accurately tested by the standardized measures available. Activities used to determine clinical judgment shall include observation and parent report and shall be described in the written evaluation report.
"Physical or mental condition which typically results in developmental delay" means a medical diagnosis:
- Approved by DHS as an eligible condition; or
- Confirmed by a qualified family physician, pediatrician or pediatric sub-specialist as being a condition with a relatively well-known expectancy for developmental outcomes within varying ranges of developmental disabilities. Pediatric sub-specialists included are those such as pediatric neurologists, geneticists, pediatric orthopedic surgeons and pediatricians with special interest in disabilities. If a child exhibits a medical condition not approved by DHS as being an eligible condition, the qualified multidisciplinary team may use written verification by one of the physician categories identified above that the child's medical condition typically results in substantial developmental delay within the varying ranges of developmental disabilities.
"At risk of substantial developmental delay, according to informed clinical judgment" means the multidisciplinary team confirms that development of a DHS-determined eligible level of delay is probable if EI services are not provided because the child is experiencing either:
- A parent who has been medically diagnosed as having a severe mental disorder as set forth under axis I and axis II of the Diagnostic and Statistical Manual (DSM) IV or a developmental disability; or
- Three or more of the following risk factors:
- Current alcohol or substance abuse by the primary caregiver;
- Primary caregiver who is currently less than 15 years of age;
- Current homelessness of the child. Homelessness is defined as children who lack a fixed, regular and adequate nighttime residence, in conformity with the McKinney Vento Homeless Assistance Act;
- Chronic illness of the primary caregiver;
- Alcohol or substance abuse by the mother during pregnancy with the child;
- Primary caregiver with a level of education equal to or less than the 10th grade, unless that level is appropriate to the primary caregiver's age;
- In indicated case of abuse or neglect regarding the child and the child has not been removed from the abuse or neglect circumstances.
"Eligibility Determination" Part C of the Individuals With Disabilities Education Act requires that a comprehensive, multidisciplinary evaluation" occur in order to determine eligibility for services. Eligibility determination requires evaluations to be completed by two separate disciplines. One person cannot complete evaluations as two disciplines. In Illinois the need for nursing, nutrition or counseling services does not determine eligibility. These are services that may require further assessment to determine need once a child has been determined eligible.
Children who present with a medical diagnosis or at risk conditions that automatically make them eligible for services must still receive a minimum of two evaluations to determine a need for services and to complete a initial comprehensive multidisciplinary IFSP. Children who are auto-eligible due to a medical diagnosis or at risk conditions may be found to be developing in a typical manner and may not require services. Evaluations will determine typical versus atypical development.
"Equally Qualified Provider" Providers who are equally credentialed/enrolled as the same discipline under the same provider category (ex., speech evaluator) are considered "equally qualified providers". In order to provide services under an existing authorization as an "equally qualified provider", the payee identified on the authorization must be an active payee on the equally qualified provider's CBO provider file(s).
"Evaluation/ Assessment" Evaluation and assessment services are for the purpose of determining initial eligibility, participating in the development of an initial comprehensive multidisciplinary IFSP, annual re-determination of eligibility, adding new types of services to an existing IFSP, and if deemed necessary, to write the report for the six month review. Initial evaluation and assessment services to determine eligibility, develop an initial IFSP or to add a new service to an existing IFSP must be provided by a provider with a credential for Evaluation and Assessment. Evaluation and assessment services provided to complete a six month review or for re-determination of eligibility on an annual basis should be provided by the direct service provider, even if that provider is not credentialed as an evaluator.
Upon completion of an evaluation or assessment, a written report of findings is required and must be submitted in the "Early Intervention Evaluation/Assessment Report Format" to the Child and Family Connections office that is working with the child/family. Providers must complete and send the entire report within 14 calendar days of the receipt of a request, including those for initial and ongoing evaluation and assessments. Incomplete reports are not acceptable and will be returned to the provider (See ATTACHMENT 1: EARLY INTERVENTION SERVICE REPORT GUIDELINES/FORMAT).
NOTES: 1) In order for a provider to receive payment for an initial evaluation to determine eligibility, the provider must also attend the initial IFSP meeting and participate in the development of the IFSP; 2) Providers are required to attend the full IFSP meeting in order to receive an authorization for payment; 3) When completing evaluations or assessments providers are required to use DHS approved tools. See ATTACHMENT 8: APPROVED ASSESSMENT INSTRUMENTS. The attached approved tool list will be posted on the EI website(s) and all newly approved tools will be added to that list; and 4) Providers must accept evaluations and assessments that have been completed prior to the initial IFSP meeting when beginning direct services. Early Intervention will not pay for the direct service provider to duplicate initial evaluations and assessments.
"Family Outcomes" The changes experienced by the family as a result of Early Intervention services and supports. Family outcomes examined include information concerning a child's strengths, abilities, and special needs and how the family helps their child develop and learn. These outcomes are measured by a survey that is sent to a portion of the families whose children receive Early Intervention services each year.
"Family Training Education & Support" Time spent with the parent/caregiver during direct service sessions only, to assist with their understanding of the child's special needs in relation to the providers discipline and enhancing the child's development. The purpose of Family Training, Education and Support is to emphasize parent participation and education to maximize a child's development. Services may consist of the following: 1) Time spent with the parent/caregiver to reflect on how the child is doing, to understand the family's priorities and concerns (parent/caregiver report), and to problem solve together to generate new ideas about how to best work with the child in the natural environment to maximize development; 2) Time to model exercises/activities that the parent/caregiver can incorporate into the child's daily activities/typical routines. This would require observation of the parent/caregivers existing methods. Examples of daily activities may include going to the grocery store, reading books, social play, etc. Examples of typical routines may include meal time, toileting, riding in the car, nap, etc.; and 3) Time spent with the parent/caregiver to develop written strategies to use with the child between direct service sessions to help meet the functional outcomes identified on the IFSP. If this document includes a complete overview of the services that were provided on the date of service that it was written, includes a time in/time out, is signed by the therapist and the parent/caregiver, and a copy is left with the parent, then this document can be considered documentation of services for billing and payment purposes (see definition of documentation). Time to complete documentation in the home that does not meet this definition is not considered "Family Training, Education and Support" time.
Family centered outcomes that are written by the IFSP team and the family based upon the family's identified priorities and concerns. Family centered functional outcomes are designed to encourage children to participate in the same types of family and community activities as other children their age. In order for this to occur the IFSP team needs to be aware of the family's routines and the community activities that the family engages in. This will allow the team to consider daily routines and a variety of natural settings for intervention strategies to be implemented once the outcomes are developed. Family participation is the key to intervention and families are more likely to participate when the outcomes are meaningful to them and can be worked on throughout their everyday routines and activities. Functional Outcomes should be written to address areas of family concern rather than focusing on specific professional disciplines or therapies. The outcome must be related to a necessary skill and should state a process and a product. Functional outcomes are developed at the child's IFSP meeting.
Family centered functional outcomes drive the decision making process to determine what Early Intervention services a child and family will receive. Service delivery decisions are not based on a child's medical diagnosis or percentage of delay, but rather on the child and family's unique strengths, needs, concerns and priorities that led to the development of each individualized family centered outcome. All outcomes must be functional and meaningful to the child and family. Family centered functional outcomes must be written prior to the determination of service delivery decisions, which would include disciplines to provide services and frequency, intensity and duration of services identified on authorizations. All recommendations for services should be based upon the PRINCIPLES OF EARLY INTERVENTION located within this document.
"Global Evaluation" A global evaluation is a general testing that is based upon the mean of a
child's age equivalent peers and is used to determine a child's status in each of the following developmental domains using standardized testing instruments approved for use by the Bureau of Early Intervention.
- physical development, including vision and hearing;
- cognitive development;
- communication development, including language and speech;
- Psychosocial or emotional development; and
- adaptive development/self-help skills.
For each domain that a DHS determined eligible level of delay or more is found, further discipline specific assessment in each of those domains must occur prior to the IFSP meeting in order to ensure that a comprehensive, multidisciplinary IFSP can be written. Because a global evaluation is a general testing of the five domains and is not domain specific, the results of a domain specific evaluation should always supersede the results of a general global evaluation.
"Group Therapy" Services provided by one or more disciplines to two or more children in a group setting. NOTE: Group size not to exceed more than four (4) children per provider. See service description "Family Training and Support" for information on the use of Interpreters for group services.
"IFSP Development" All IFSP development activities identified below must be completed by the credentialed, enrolled provider, with the exception described below (see number 3 for exception.) Plan development includes attendance of the initial/annual Individualized Family Service Plan (IFSP) meeting as a member of a child/family's service team to assist in the completion of a written document on the statewide Service Plan form detailing individualized outcomes for the child and family, services based upon the unique needs of the child and family, and transition strategies. Provider can attend the meeting in person or be present by conference call. Providers must accept responsibility for phone charges for IFSP conference calls if done for their convenience. Providers are required to attend the entire IFSP meeting in order to receive authorization for payment. After the initial service plan is implemented, IFSP development includes:
- Periodic review of a child's IFSP every six months or more frequently if conditions warrant, or if the family requests such a review, to determine if adjustment of the IFSP is needed. Periodic reviews must be conducted as defined in 34 CFR Parts 303.342 and 303.343. At a minimum, the child's parent(s), other family members as requested by the child's parent(s), an advocate or person outside of the family if requested by the parent(s) and the child/family's service coordinator must be present at each periodic review. Meeting arrangements and written prior notice for each periodic review must be made to the family and other participants early enough before the meeting date to ensure that the participants will be able to attend. Meetings must be held in settings and at times that are convenient to the family and in the family's native language or other mode of communication used by the family, unless it is clearly not feasible to do so.
- Attendance at the transition meeting, if required.
- Attendance at a child's IEP meeting if the meeting occurs prior to the child's third birthday. NOTE: EI does not pay for attendance at pre-IEP meetings.
- The development of a direct service report required for the six-month review, or more frequently if conditions warrant a periodic review at a time other than at six months or if a review is requested by the family. This report would be a summary of a provider's record notes.
Effective February 2004, an exception to the requirement that all IFSP Development activities be provided by the credentialed, enrolled provider was implemented. If direct services are provided by an associate level provider under the supervision of a credentialed, enrolled professional, the associate level provider may summarize his/her record notes and develop the direct service report required for the six-month review if licensing laws that govern the supervisor's discipline allows. However, the credentialed, enrolled provider who supervises the associate must document that he/she has reviewed and agrees with the report and must sign the report as the Associate's Supervisor.
Early Intervention has always required that all evaluations and assessments be completed by a credentialed, enrolled provider. Evaluation/ assessment reports are billed under the evaluation/ assessment procedure codes and must be completed by the credentialed, enrolled provider who actually provided that service.
The development of a discharge report by the credentialed, enrolled provider. NOTES: 1) Time used to develop the report must be documented in case notes; 2) The content of the report must justify time billed to and paid by the CBO: and 3) Evaluation/assessment reports are billed under evaluation/assessment procedure codes.
- Time for a Physical Therapist, Occupational Therapist, Audiologist, or Speech Therapist Evaluator to write a letter of developmental necessity for the CFC to submit to DHS for Assistive Technology (AT) prior approval. All requests for AT must include all required information. If a direct service provider determines a possible need for AT devices, the provider should call the child's service coordinator to recommend that AT be added to the child's IFSP. The service coordinator will call a meeting of the IFSP team to discuss the need to add a new service to the IFSP. If the team determines that there is a need, and the direct service provider is also a credentialed/enrolled evaluator, then the evaluator will write the letter of developmental necessity to submit to the service coordinator for AT prior approval purposes. This time is billed as IFSP development time.
If the direct service provider is not a credentialed/enrolled evaluator, then the service coordinator will generate an evaluation authorization to a credentialed/enrolled evaluator who will complete an evaluation and develop the letter of developmental necessity to submit to the service coordinator for prior approval purposes. The evaluator will bill for this time under the evaluation procedure code identified on the authorization.
- Time for a provider who is requesting a change to the frequency or intensity of an existing service authorization to write the required justification of need that will be attached to the form entitled "Justification to Change Frequency/Intensity". The written justification must be written and signed by the provider who has requested the change and the content must justify the time billed to and paid by the CBO.
- Provider to provider consultation performed by the credentialed, enrolled provider among members of the child's service team who are identified on the service plan as providers of EI services, the CFC parent liaison, the CFC social emotional consultant, the service coordinator and the child's physician concerning the child's developmental needs or the impact of special health care needs on services. Providers should always document this time accurately and should identify the EI provider or physician who was consulted in their documentation.
After the child/family has received a assistive technology device, consultation includes conversations held with the vendor concerning the fit and/or use of the device.
NOTES: 1) IFSP Development does not include time to speak to a child's parent(s) on the telephone. Time to speak to a child's parent(s) on the telephone is not considered provider to provider consultation and is not billable time. Providers should speak to a child's parent(s) during face-to-face direct service sessions. If the parent(s) cannot be present during a normally scheduled direct service session, providers should schedule an occasional direct service session at a time when the parent(s) can be present.
- IFSP Development does not include supervisory time; routine preparatory activities such as time spent packing or washing toys, file review and/or review of record notes or development of lesson plans or activity plans prior to each incident of service; time to leave a voice message; scheduling and canceling appointments, including time to speak to the interpreter who will schedule and cancel appointments for the discipline who they are interpreting for; time to write reports other than those identified in numbers four (4) and five (5) above; or family training, education and support which is an activity identified under each service description where appropriate. The activity "Family Training, Education, and Support" is built in to all services and is only billable under individual treatment and group procedure codes, not IFSP Development codes. (see ATTACHMENT 7: NON-BILLABLE ACTIVITIES)
- Providers are required to maintain daily documentation for all IFSP Development time based upon date of service and type of service. For IFSP development time only, a provider can bundle multiple dates of service together to equal a 15 minute unit. Bill using the last date added to the bundle as the date of service. All dates of service bundled into a single date of service for payment must all fall within the 90 day billing time frame.
"Make Up Session" A provider can reschedule a missed visit based upon the guidelines stated below:
- If a weekly or monthly service session cannot be rescheduled within seven (7) days from the original scheduled date, it should be considered a missed session.
- If a provider knows that a service will be missed prior to the regular date of service due to an upcoming vacation or hospitalization, the provider may complete the service seven (7) days prior to the missed date. If more than one date of service will be missed due to vacation or hospitalization, it should be considered a missed session.
- Given the frequency of illness in young children, family and provider vacations, and other unforeseen issues, missed sessions are inevitable. However, they should not be routine occurrences. Providers should make every effort to avoid missing service sessions.
- Never provide a make up session on the same date that a regular session has been scheduled or as back to back sessions, as most birth to three children would be unable to tolerate an extended session.
- If it is necessary for a provider to miss a number of service sessions due to an extended vacation or a prolonged illness/injury, etc., an equally qualified provider must be identified to carry out the services identified on the IFSP. The provider should contact the family and the service coordinator for each child on his/her caseload and work with the service coordinator to find a substitute for each child.
- Always document in your case notes the date of the missed visit, the reason for the missed visit and if you reschedule based upon the above guidelines. When completing documentation after a make up session, include information in the documentation that identifies the date of service as a "make up session".
- Always bill for a make up session based upon the actual date of service, not the date of the missed session.
"Multidisciplinary" The involvement of two or more disciplines or professions in the provision of integrated and coordinated services, including evaluation and assessment activities and development of the IFSP.
"Natural Environment" A setting that is natural or normal for a child's age peers who have no disability.
"Need" A condition or situation in which something is essential, necessary or required.
"Outcome" A statement of the benefits and changes that the multidisciplinary team expects for the family. Outcomes are discipline-free (see definition of functional outcomes).
"Priorities" A family's choices and agenda for how Early Intervention will be involved in the family life.
"Resources" The strengths, abilities, and formal or informal supports that can be mobilized to meet the family's concerns, needs, or outcomes.
"Strengths" Individual characteristics that can be used as a resource.
"Want" A preference or end result that is not essential, necessary or required.
"Written Home Activity Program" A written home activity program is a document that is written in the home or other place of service, with the input of the parent/caregiver during a direct service session. It should identify developmental strategies to meet functional outcomes that are important to the family and that support the family in developing or refining their ability to facilitate their child's active involvement in his or her community and family. This document should be shared with all members of the IFSP service team and the parent/caregiver and is considered to be family training, education and support time and is billable as direct service time only.
"Written Developmental Justification of Need" A written developmental justification of need should be written in narrative form and must clearly state the developmental needs that drive the recommendation for services(s) and how each recommended service is required and designed to meet the functional outcomes that have been identified in the child/family's service plan. Each child/family's unique strengths/developmental needs should be reflected in the written developmental justification of need. A written developmental justification of need is not a form letter and must be written based upon the Guidelines/Worksheet found in ATTACHMENT 3: DEVELOPMENTAL JUSTIFICATION OF NEED GUIDELINES AND WORKSHEET of this document.
For Associate Level Providers, work performed under the guidance and direction of a supervisor who is responsible for supervision of the work, who plans work and methods, who is available on short notice to answer questions and deal with problems that are not strictly routine, who regularly reviews the work performed and who is accountable for the results as set forth more specifically in ATTACHMENT 4: USE OF ASSOCIATE LEVEL PROVIDERS of this document. Supervisory time is non-billable time and is considered to be administrative time that is included in the rate paid for direct service.