Highlighting Two States' Approaches to Telehealth for Early Intervention

Highlighting Two States' Approaches to Teleheath for Early Intervention

Original Publish Date: April 24th, 2020


COVID-19 has resulted in states scrambling to re-imagine the delivery of early childhood programs and services, including many programs shifting to virtual methods of delivery. The pandemic is highlighting ways states are bolstering and adjusting to distance-based IDEA Part C early intervention services. Some level of access to and continuity of early intervention services for families with infants and toddlers with developmental delays and disabilities is essential during these times given the critical importance of the first three years of a child’s life.

In Colorado, early intervention via telehealth was already being provided prior to the COVID-19 outbreak, allowing for the state to build off its already existing infrastructure. In Illinois, state partners and advocates worked tirelessly to make video-based early intervention services feasible and billable during the pandemic. Both states have responded to the COVID-19 crisis with comprehensive guidance on delivering telehealth, and important key components from these two examples are highlighted below.

Before Providing Telehealth: Before early intervention services can be provided via phone or video platform, both Colorado and Illinois require providers to take a pre-identified training that’s available online on how to successfully deliver telehealth services. Both states require obtaining family consent prior to delivering telehealth. Given the current times, Colorado does not require the telehealth consent form be signed before a provider can begin telehealth visits, but does require that verbal consent be obtained and documented. Illinois’ policy states that if technology limitations do not allow for obtaining a digital signature, then an option for verbal consent is available. Both states have a standardized consent form – Colorado’s is available in both English and Spanish; Illinois is working on translating their form to Spanish and Chinese.

Intake and Services: Both Colorado and Illinois allow for intake activities to be done virtually. Illinois provides additional guidance that all intake forms need to be securely emailed, faxed, or mailed to families with sufficient time (5-7 days) to receive the documents prior to their intake meeting. Illinois indicates that intake timelines continue to hold, whereas Colorado explicitly indicates that the COVID-19 pandemic is considered an “exceptional family circumstance” that needs to be indicated if the initial evaluation is not able to be performed within the 45-day required timeframe.

Colorado is allowing assessments and evaluations to take place virtually. For evaluations, guidance indicates the need to consider efficacy of gathering information in a virtual format and that it may not always be appropriate – for example, Colorado offers separate guidance for hearing and vision screenings. Colorado guidance also recommends that a combination of the following be considered for each evaluation: interviews with caregivers; review of existing developmental information including videos of the child, if available; virtual observation of a play session or other routine; guiding parents in simple activities that can then be reviewed together; and direct assessments that are able to be conducted in an interview format. In Illinois, children who are automatically eligible for early intervention based on a medical diagnosis or meeting the at-risk criteria are able to receive an assessment via video using parent interview, observation, and informed professional judgment. However, Illinois is not currently allowing evaluations via video for children who might be eligible due to a developmental delay, and is actively working to figure out if this might be modified in some way.

Both Colorado and Illinois allow all IFSP meetings to be conducted virtually by phone or video.

Privacy, Security, & Platforms: Colorado and Illinois have tackled the privacy and security issues in slightly different ways. Perhaps since Colorado already had telehealth established, they promote the use of Zoom for telehealth as a HIPAA and FERPA-compliant platform. However, Colorado is currently considering additional guidance around other free platforms that are also HIPAA compliant, such as Doxy.me. When Zoom is not an option, they defer to federal guidance related to the good faith provision of telehealth during the COVID-19 nationwide public health emergency, allowing for FaceTime, Facebook Messenger video chat, Google Hangouts video, or Skype to provide telehealth without risk of noncompliance with the HIPAA rules. However, FERPA must also be considered in Colorado, and providers are advised to check with their professional organizations on this. Colorado allows for recording of sessions after families sign a consent to record form.

Illinois is allowing providers to use any platform with the exception of any public-facing platform (e.g. Facebook live, Instagram, TikTok). Illinois explicitly states that not all platforms are HIPAA/FERPA vetted, so the onus is on providers and families to understand the risks. Illinois’ guidance also explicitly speaks to security issues and primarily puts the responsibility on families to keep information about themselves and their children private. That said, certain measures have been put in place to ensure security including the prohibition of recording video-sessions and ensuring good-faith efforts that telehealth services are occurring in areas where people cannot hear or observe conversations between the provider and the family.

Billing: Both Colorado and Illinois provide guidance on how to bill for telehealth through Medicaid including the applicable billing codes, and both states provide guidance on billing private insurance. Colorado’s guidance also indicates what types of virtual activities are and are not billable, and overall, indicates that reimbursement rates should mirror reimbursement for in-person visits; Illinois indicates that reimbursement rates will be the same as offsite direct service visits.

Equity: Both Colorado and Illinois recognize that a significant equity challenge for telehealth is around access to devices and internet. Colorado has information on access to internet essentials through a major internet provider. Illinois has gone a step further to address the digital divide by identifying a variety of resources to help families access low-cost computers and devices, mobile service, as well as free or low-cost internet. However, families who face significant systemic barriers to accessing early intervention in general – whether due to race, income, immigration status, housing security, connection to child welfare, etc. – may be more likely to face challenges with accessing telehealth due to a variety of factors that aren’t solely contingent on access to technology. While telehealth is a vital mechanism for ensuring some access to and continuity of early intervention services, additional COVID-19 related stressors and inequities across multiple family-serving systems may result in growing challenges around access to early intervention. As states quickly shift to telehealth, data including demographic data must be collected to understand access and barriers to early intervention services during this time.

Colorado and Illinois provide excellent models on how to quickly adjust to telehealth services during this pandemic. Pairing telehealth with innovative, alternative ways to continue to stay connected to families to best support their children will be essential during this time. And, communications with families, pediatricians, child care providers, and others are important so they know that early intervention is still available.

Be sure to check-out this blog by Ounce National Policy Team’s Policy Manager Emily Powers that highlights some innovative ways that states are thinking about early intervention during COVID-19.


This blog is shared on the Early Childhood Connector (ECC) News to support the goal of elevating community voices. The highlighted Community Blog in this post was originally shared by Mina Hong in the COVID-19 Community group. Share how COVID-19 has affected you, your community, your state, and our country by joining the community.

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