To accomplish this training requirement you obviously need to have sufficient staff and sufficient time to do what is written in the plan of care and write it down. If one of those clients engages in highly disruptive behaviors throughout the five hour period that require the one staff person to intervene, you cannot bill for a client if the person did not receive the training written in his or her plan of care. And any time such a staff person requires a break, they must be replaced by a second staff person who is likewise prohibited from working with anyone else. A Medicaid review of a data sheet that showed 9 AM- 3 PM would be interpreted as meaning that training was provided continuously for six hours, which obviously would almost never be true. If a simple observation were to be made during such a recorded time frame, and only intermittent training were to be seen, then the documentation would be considered incorrect and repayment would be demanded by the Division.
Frequency is equally important.
You cannot use such terms as up to or as needed on the adult waiver objective page for frequency. Do not write daily or weekly or monthly under frequency. If you write every Wednesday under frequency, the procedure must take place every Wednesday in order to be billed. One time per week is better because it gives the provider the flexibility to choose what day to provide the service. A provider can never bill for more units in a specific time frame than is shown in duration and frequency, and if they bill for less they could be failing to do what is in the plan of care .