COVID-19 SHARS and MAC Program FAQs

TASB Special Education Solutions has fielded many calls concerning SHARS and MAC over the last couple of weeks. We’ve done our best to address the various questions that have come up on a case-by-case basis. We have reached out to Texas Education Agency (TEA) and Texas Health and Human Services (HHSC) along the way for clarification as well. For many of these inquiries, we are awaiting additional information.

We will work to keep these FAQs as updated as possible as we get more information in.

Contact for questions.

SHARS overall

What dates are billable for teletherapy through SHARS during the COVID-19 pandemic? (Updated) Do I have flexibility to change my SHARS/MAC program because of recent changes due to COVID-19? Can I continue to bill for SHARS while my school is delivering alternative instruction? We have heard that providing services, supports, or therapy virtually is in violation of FERPA or HIPPA. Since there is guidance from the federal level that indicates a priority toward delivery of services virtually, may we bill for all areas of SHARS? Given that there is national support for teletherapy during the current crisis, may we deliver and bill for physical therapy (APTA), counseling (ACA & ASCA), assessment (APA), psychological services (APA), nursing (NASN), occupational therapy (AOTA), speech services (ASHA), etc..? As a school district, are we eligible to apply for the Provider Relief Fund? (Updated) If we receive a payment from the Provider Relief Fund, how should it be coded in our accounting records?

SHARS service areas

May we bill for teleservice for speech and occupational therapy? May we provide supervision for our Speech Therapy, Occupational Therapy and Physical Therapy Assistants virtually? May our Speech Therapy, Occupational Therapy, Physical Therapy, and Audiology Therapy Assistants deliver services virtually and seek reimbursement through SHARS? May we evaluate or assess students virtually and bill SHARS during this time? During the COVID-19 pandemic, should Psychologists and LSSPs bill for counseling as a related service under Counseling or Psychological Services? May we bill for personal care services if our staff are providing services virtually?

Billing specifics

What is required or typical activity for a billable telehealth session? We are working with a contractor to deliver services virtually. May we bill for services delivered via a contractor? May we bill for services that are provided and include the parent or caregiver to assist? May we deliver service via the telephone and seek reimbursement through SHARS? (Updated) Due to confidentiality issues, must teleservices for counseling be face to face, or can the sessions be conducted by phone as this allows for some level of confidentiality? (Updated)


Do you need informed consent for each service or one for a student and all services they are receiving? Must we get a new consent to deliver services virtually? May we attain parental consent for SHARS virtually? May we document parental notification of SHARS billing virtually?


If the Annual is not due until November, does our staff need to have an amendment change of placement to document that they have received informed consent from the parent for telehealth services? If your IEP states you get physical therapy (or any other therapy) one time a month for 30 minutes but you are now doing teletherapy once a month for only 15 minutes, does an ARD need to be held to adjust the minutes to be able to bill? How can school staff document that they are providing services through teleservices for SHARS billing purposes? Should we change a student's IEP to outline services being delivered during the current crisis? We have decided that our staff will continue to document for SHARS. Is there something else we should do in that documentation to support billing SHARS?

Regulatory requirements

How should we address moments when staff have been chosen to respond for the random moment time study (RMTS) requirement? We have been given approval to virtually sign our FY 2019 Cost Report. However, the document does not have a place for us to execute this online. How do we meet this requirement? Our community is under a stay-at-home order. How can we complete the Certification of Funds (COF) requirement during this time as the letter is mailed to our district offices and no one is reporting on site? (Updated) I have heard that the federal government has approved a different FMAP for services provided during this time. Does this impact SHARS or MAC? Our provider enrollment revalidation is due, but we are focused on serving students. What can we do? (Updated) We are unable to bill during this time due to various limitations. Will HHSC inactivate our TPI resulting in our removal from the SHARS or MAC program? Our community is under a stay-at-home order. How can we complete the required notary requirement for documentation?

If you have additional questions, we are here to help.  Please reach out to us at We will do our best to assist all Texas school districts.