Infant development programs in OT, PT and SLP practices

Pediatric OT, PT and SLP practices serving babies and toddlers under 3 should decide, before advertising, which of three things a program is: skilled therapy, with an evaluation, a plan and goals; a parent class, which diagnoses no one and bills no payer; or Part C early intervention, the state’s public program. Then describe it as exactly that.

Everything here concerns children from birth to their third birthday. Practices that also serve adults keep those services on their own pages; the children-and-adults guide covers serving both from one practice.

What counts as an infant development program in a therapy practice?

Three different services share the name, and each one a practice offers has to say which it is. Skilled therapy starts with one baby’s evaluation and leads to a plan of care with goals the clinician measures. A parent education class teaches caregivers general information from published sources, evaluates no one and is not billed as therapy. Part C early intervention is the program each state runs under IDEA for children under three; its services are developmental services provided under public supervision, selected in collaboration with the parents and delivered under an individualized family service plan (IFSP).⁠¹

The labels matter because a class described as therapy invites a family to skip an evaluation the baby may need, and anything described as early intervention suggests a public program. One practice can run all three if each is booked, documented and described on its own. Referrals of babies born early or sick are covered in the NICU follow-up guide.

How do skilled therapy, a parent class and Part C compare side by side?

They differ at every step, from who may join to who pays.

What should a practice decide before launching an infant program?

Eight things, each written down before anything is advertised.

The AAP explains that, for the first 2 years, corrected age is the better guide to when a baby born early should reach common developmental goals.⁠¹⁹ Testing demand is covered in the specialty guide, and service-page structure in the pediatric service pages guide.

What makes an infant program skilled therapy rather than education?

An evaluation of one baby by a licensed clinician, followed by a plan of care with goals the clinician measures and revises. ASHA’s list of SLP roles in early intervention shows the shape: culturally responsive screening, evaluation and assessment; reporting treatment outcomes and documenting progress; and revising plans and setting discharge criteria.⁠⁴ An APTA Pediatrics fact sheet describes pediatric PT the same way, as episodes of care with clear entry, exit and reentry criteria.⁠²⁰ An OT plan of care is set under the OT practice act and the payer’s rules.

The line between teaching and treating shows in a common concern. An APTA Pediatrics fact sheet on infant head shape puts parent education, repositioning and exercises first for babies 0 to 4 months without torticollis, developmental concerns or obvious skull deformities, and asks for a referral for a physical therapy or cranial orthosis evaluation when a baby resists repositioning, shows neck tightness or movement asymmetries, or the head shape worsens or does not improve.⁠²¹ General tummy time teaching belongs in a class; a positioning program for one baby with neck tightness is therapy.

The family hears its own baby’s findings in private and agrees to the plan: ASHA requires informed consent about the nature, risks and effects of services, APTA’s code obliges PTs to give patients, or surrogates such as parents, what they need to make informed decisions, and AOTA’s code names autonomy among its guiding principles.⁠^12,22,23

How is skilled therapy for babies and toddlers paid for?

By a payer whose medical-necessity rules the baby meets, or by the family. For a Medicaid-enrolled child, EPSDT obliges the state to cover each 1905(a) service that is coverable, appropriate and medically necessary to correct and ameliorate health conditions.⁠²⁴ Under 42 CFR 440.110, Medicaid PT and OT are services a physician or other licensed practitioner prescribes, while speech, hearing and language services are ones a practitioner refers the patient for.⁠²⁵

Referral rules differ by discipline. All 50 states, DC and the U.S. Virgin Islands allow direct access to physical therapists in some form, with limits that differ by jurisdiction, and an APTA Pediatrics fact sheet notes that a physician referral may still be needed for reimbursement.⁠^20,26 For OT and SLP, read the plan’s policy and your practice act rather than borrowing the PT rule. A family paying privately usually receives a good faith estimate if they ask or book at least 3 business days ahead; the insurance and fees guide covers explaining costs.⁠¹⁶

What can a parent education class for babies teach?

General information a primary source states, taught to caregivers who stay with their own babies, with every question about one baby routed elsewhere. CDC says parents, grandparents, early childhood providers and other caregivers can take part in developmental monitoring, using free milestone checklists, and the AAP’s surveillance report includes two-way communication with early childhood programs, parenting programs among them.⁠^5,27

Each discipline’s association supplies content. An SLP can teach the birth-to-2 habits on ASHA’s consumer page, now hosted by the Communication Health Support Association, such as talking back when a baby makes sounds, using gestures and talking through bath, feeding and dressing, in any language the family uses, and ASHA counts prevention and early identification activities among SLP roles.⁠^4,28 A PT or OT can teach the AAP’s tummy time guidance, below.

A class does not give findings about a baby, tell a family their baby is on track, replace screening or a Part C evaluation, or bill as therapy, and a topic with no primary source stays out. Talks outside the clinic are covered in the PTA presentations guide.

Which safe sleep points can an infant class teach from the AAP?

The AAP’s own list, in its own words, with the AAP’s page in each family’s hands. The AAP’s 2022 policy statement recommends supine positioning, a firm, noninclined sleep surface, room sharing without bed sharing, and avoiding soft bedding and overheating.⁠²⁹ Its parent page adds points a class can read out as written:⁠⁸

• Place the baby on their back for all naps and at night.
• Use a crib, bassinet, portable crib or play yard that meets CPSC safety standards, with a fitted sheet only.
• Share a room for at least the first 6 months, without sharing a bed.
• Use no weighted blankets, weighted sleepers or weighted swaddles, and no products for sleep that are not made for infant sleep.
• Move a baby who falls asleep in a car seat, stroller, swing or sling to a firm sleep surface on their back as soon as possible.

In your room, a baby who falls asleep goes back to their caregiver or a safe sleep surface, never onto a nursing pillow. Questions about one baby’s sleep go to the pediatrician, as the AAP’s page advises; it states that even babies with gastroesophageal reflux disease (GERD) should sleep flat on their backs, and the class adds nothing to that.⁠⁸

How should a class teach tummy time without giving clinical advice?

By teaching the AAP’s general schedule and sending any baby who struggles, favors one side or has a flat spot to the pediatrician. The AAP’s page says tummy time is for babies who are awake and closely supervised, can start the day the baby comes home, begins with 3 to 5 minutes 2 to 3 times a day and works up to 15 to 30 minutes a day by 7 weeks; it also advises limiting time in swings, bouncy chairs and car seats.⁠⁹

An individual positioning program is therapy. The APTA Pediatrics head-shape fact sheet states that an abnormal head shape continuing beyond 6 weeks of age should be evaluated by a physician, and lists restricted neck and shoulder range of motion, and no head-shape improvement after a month of caregiver repositioning and tummy time, among the indications for physical therapy.⁠²¹ A leader who notices a baby always turning one way says so privately and suggests the pediatrician.

How should a class leader answer a question about one baby?

Briefly, privately and with a route rather than an opinion. CDC tells families to talk with the child’s doctor and, while asking for a referral, to call the state’s public early childhood system for a free evaluation, without waiting for a doctor’s referral or a diagnosis.⁠³⁰ Give the family that route in writing.

Can a parent class be billed as caregiver training?

Not as an open class. The CPT descriptors for caregiver training describe training in strategies and techniques to facilitate the patient’s functional performance, without the patient present, with 97552 for multiple sets of caregivers at once.⁠³¹ Medicare, as one payer, covers it when a therapist furnishes it as part of the patient’s individualized treatment plan or therapy plan of care; other payers set their own terms.⁠¹⁰ An open class has no patient, plan or goals, and its babies are in the room, so it is sold as education. Caregiver training for families of babies in therapy is billable only where each baby’s plan calls for it and the payer covers it; group formats are in the therapy groups guide.

How does IDEA Part C early intervention differ from your program?

Part C is a public program with its own eligibility, team and plan, and a private program sits beside it, never in its place. Part C serves children under three who need early intervention because of a delay, measured with appropriate diagnostic instruments and procedures, or because of a diagnosed physical or mental condition highly likely to cause one; states may add at-risk infants.⁠¹⁴ Each state runs its own program, with its own rules about eligibility and services.⁠¹⁵

Some functions are always free to parents, among them child find, evaluation and assessment, service coordination, and the work of developing and reviewing IFSPs. Other services may carry fees under a written state system of payments, but a family the state defines as unable to pay gets every Part C service at no cost.⁠² Parents can accept or decline each service, and decline one later without losing the others.⁠¹⁷

Families can use both. An IFSP must list medical and other services the child gets from other sources, and ASHA names private practices among the settings outside Part C, billing public or private insurance or the family.⁠^3,4 Timelines and coordination are covered in the NICU follow-up guide. Your practice is also a referral source: the regulation counts "other clinics and health care providers" among primary referral sources, and state procedures must have a child referred no more than seven days after being identified, so print the program’s number on every handout.⁠³²

Can a private infant program call itself early intervention?

Only with care, because families read the words as the state program. CDC uses "early intervention" as the general term for services and supports for babies and young children with delays and disabilities, and describes the state programs as publicly funded, free or reduced-cost for eligible children.⁠¹⁵ Under Part C, an early intervention service provider is one providing services under Part C, delivered under public supervision and in conformity with an IFSP; a private class or therapy program is neither.⁠^1,18

The FTC’s impersonation rule makes it an unfair or deceptive practice to materially misrepresent, directly or by implication, affiliation with a government entity, including its endorsement or sponsorship.⁠¹³ Avoid names such as "Early Intervention Center" for a private program, never use the state program’s name or logo as yours, and say plainly that the class is not part of it. A contracted Part C provider says so only about services under an IFSP, and keeps those records and bills apart.

Where do developmental monitoring and screening fit in an infant program?

Monitoring is something families can do; screening is a formal step, usually at well-child visits; evaluation comes next, at a practice or through Part C. CDC describes screening as using formal, research-based questionnaires or checklists about a child’s language, movement, thinking, behavior and emotions.⁠²⁷

The AAP’s 2020 clinical report supports surveillance at every health supervision visit and standardized screening at the 9-, 18- and 30-month visits, with concerns at any visit followed by screening or direct referral to intervention and specialty care.⁠⁵ Its 2020 autism report recommends standardized autism screening in primary care at 18 and 24 months, while noting that other settings may perform it.⁠⁶ CDC tells parents they can ask their child’s provider to screen if it has not been done, advice a class can repeat to every family.⁠²⁷

A screening event is a separate service from a class. ASHA describes screening as identifying children who may need further evaluation, with results leading to rescreening, comprehensive assessment or referral.⁠⁴ Free still has rules: OIG’s 2016 statement explains that remuneration under the beneficiary inducement statute includes services given for free, and that offering Medicare or Medicaid beneficiaries remuneration likely to sway which provider they pick, when the provider knows or should know it, can expose the provider to civil monetary penalties.⁠³³ The handwriting program guide covers structuring a free screening.

How should a class use CDC’s milestone checklists?

As conversation tools families take to their pediatrician, never as a test the class gives. CDC calls them communication tools intended to encourage conversations between families and professionals, says the milestones are not developmental standards or screening tools, and says they should not establish medical necessity for services; milestones sit at ages by which at least 75 percent of children would be expected to show them.⁠⁷ CDC’s parent page adds that the checklists are not a substitute for validated screening tools.⁠³⁰ Adding a practice’s name to CDC materials is covered in the PTA presentations guide.

What does each discipline offer babies and toddlers?

Each discipline brings its own part, so name the discipline in every description rather than offering generic "infant therapy."

AOTA’s practice guideline for birth to 5 years found interventions within OT’s domain that support cognitive, social-emotional, motor and self-care skills, some of which parents can implement after training.⁠³⁶ That supports coaching inside a plan of care, not selling a class as treatment. Each clinician stays within their competence: ASHA’s code requires clinical services to be provided competently, and APTA’s requires PTs to maintain professional competence.⁠^12,22

Who handles infant feeding questions in an infant program?

An SLP or OT with infant feeding training, inside an evaluation, never a class leader answering from the floor. ASHA names SLPs the preferred providers of dysphagia services, working within an interprofessional team; its infant evaluation looks at prefeeding skills, readiness to feed by mouth, breast or chest feeding and bottle feeding, and how caregivers feed the baby, and its team list for infants includes a lactation consultant.⁠³⁷ AOTA states that OT practitioners play a crucial role in feeding, eating and swallowing challenges at every age.⁠³⁸ Name, before the first class, the clinician each kind of feeding question goes to; the feeding and swallowing guide covers competence and red flags.

What staffing and space does an infant program need?

A named clinician with infant training for each offering, enough adults that no baby goes unwatched, and a room built for caregivers with babies on laps and mats. The NICU follow-up guide has an infant-competence checklist for each clinician.

The room needs clean mats and washable toys with a written cleaning routine between sessions, space for strollers and car seats, a changing area and a private space for feeding. Keep each baby with their own caregiver throughout, and cap the number of families by how many babies one leader can watch at once, since the AAP’s tummy time guidance is for babies who are closely supervised.⁠⁹ Keep sleep products out, since the AAP advises against products for sleep not made for infant sleep.⁠⁸ Assistant supervision and disability access are covered in the therapy groups guide.

How do consent and HIPAA work in a group class for babies?

The parent decides for the baby, sign-up collects as little health information as the class needs, and the leader discusses no baby in front of the group. In most cases, HHS explains, a parent is the personal representative of a minor child, because the parent usually has authority to make the child’s health care decisions.⁠³⁹

HIPAA reaches a health care provider only when it sends information electronically in a transaction for which HHS has adopted a standard; an entity outside the definitions need not comply with the HIPAA Rules.⁠⁴⁰ For a covered practice, health information it receives about an identifiable person, class attendee or patient, is individually identifiable health information.⁠⁴¹ A form asking whether a baby was born early collects exactly that, so ask only for the age band, contact details, language and what safety requires. A practice outside HIPAA checks its state’s privacy law first.

In a skilled therapy group, HHS treats what is shared as treatment disclosures needing no authorization and reads agreement to join as a good basis for inferring agreement.⁠⁴² A class is not therapy, so set the expectation in writing instead: families see who attends and hear what is said, and nobody’s baby is assessed aloud. Group agreements are covered in the therapy groups guide.

Can you photograph babies in a class or therapy group?

Only with signed permission from the parent of every baby in the frame, and from every adult, and for a patient that permission is a HIPAA authorization. Unless another provision of the Privacy Rule permits it, a covered entity needs a valid authorization to use or disclose protected health information, and posting a patient’s photo to promote the practice is no exception.⁠⁴³ Use a form for class attendees too, saying what is posted, where and for how long, and letting families refuse without losing their place. A paid DrSensory listing can carry up to five photos, each needing the same permission.

How do you describe an infant program without promising outcomes?

Describe what happens, who leads it, which babies it suits, the price and its limits, and leave out any result you cannot support. Under the FTC’s guide for small businesses, an ad has to be truthful and non-deceptive, the advertiser needs evidence for each claim, most health or safety claims must rest on competent and reliable scientific evidence, and happy customers’ statements rarely suffice.⁠¹¹ The FTC judges an ad’s net impression, including its product name, by what consumers understand rather than what the marketer intended, so a class called "Baby Brain Boost" makes a claim through its name alone.⁠⁴⁴

The professional codes agree. ASHA allows a reasonable statement of prognosis but bars promising treatment results directly or by implication, and bars misrepresentation in advertising; APTA requires truthful, accurate and relevant information without misleading representations; and AOTA’s code of ethics lists veracity among its guiding principles.⁠^12,22,23 Do not market normal variation as a disorder: CDC’s checklists do not contain every milestone a child might show.⁠⁷

How should an infant program appear on a DrSensory listing?

As the clinic’s own description, with the ages and services that are true today. DrSensory is a free directory families use to find OT, PT and speech therapy clinics for children and adults; it lists clinics rather than individual therapists, and every clinic is listed free at a basic level. A paid listing adds the clinic’s own description, a logo, up to five photos, hours, specialties, ages and conditions treated, a website link, reviews with public replies, and inquiries from families sent straight to the clinic. Say there which offering is therapy and which is a class. DrSensory does not promise rankings or verify clinical quality, so the listing needs your website’s honest wording; the profile guide covers claiming, which is free.

What should an infant class plan include, session by session?

Everything the leader needs to teach the same sourced content each time, and everything the class does not do, written before the first session.

What should a parent-facing program description say?

Who it is for, what happens, who leads it, what it is not, what it costs and where to go with a concern; replace every bracket.

How does one clinic run a class and a therapy track side by side?

By separating them from the first flyer onward; one clinic’s hypothetical launch shows the order of decisions.

Sources

1. eCFR, 34 CFR 303.13. Early intervention services (IDEA Part C regulation, current as of October 22, 2026). Checked October 23, 2026.
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   “Early intervention services means developmental services that— (1) Are provided under public supervision; (2) Are selected in collaboration with the parents;”; “(9) Are provided in conformity with an IFSP”; “Occupational therapy includes services to address the functional needs of an infant or toddler with a disability related to adaptive development, adaptive behavior, and play, and sensory, motor, and postural development.”.
2. eCFR, 34 CFR 303.521. System of payments and fees (IDEA Part C regulation, current as of October 22, 2026). Checked October 23, 2026.
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   “The following are required functions that must be carried out at public expense, and for which no fees may be charged to parents:”; “Evaluation and assessment, in accordance with § 303.320”; “Service coordination services”; “if the parent or family meets the State’s definition of inability to pay, the infant or toddler with a disability must be provided all part C services at no cost.”.
3. eCFR, 34 CFR 303.344. Content of an IFSP (IDEA Part C regulation, current as of October 22, 2026). “Identify medical and other services that the child or family needs or is receiving through other sources, but that are neither required nor funded under this part”. Checked October 23, 2026.
4. American Speech-Language-Hearing Association. Early Intervention (ASHA Practice Portal professional topic). Checked October 23, 2026.
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   “EI services can also be provided outside of Part C programs in settings such as neonatal intensive care units, pediatric rehabilitation hospitals or clinics, preschools, and private practices. Services in these settings may not be covered by federal or state dollars but may be billed to public or private insurance or to the family.”; “SLPs in EI are qualified to provide services to families and their young children who demonstrate, or are at risk for developing, delays or disabilities in communication, speech, language, cognition, emergent literacy, and/or feeding and swallowing.”; “Engage in prevention and early identification activities to promote healthy development and reduce risk factors that can impact a child’s development.”; “Conduct culturally responsive screening, evaluation, and assessment to identify young children with, or at risk for, a delay or disorder.”; “Gather and report treatment outcomes and document progress.”; “Revise intervention plans and determine discharge criteria.”; “Screening refers to the process of identifying children who may need further evaluation to determine the presence of a developmental delay or disability.”; “Screening may result in recommendations for rescreening, comprehensive assessments, or referral for other examinations or services.”.
5. Lipkin PH, Macias MM; AAP Council on Children With Disabilities, Section on Developmental and Behavioral Pediatrics. Promoting Optimal Development: Identifying Infants and Young Children With Developmental Disorders Through Developmental Surveillance and Screening (AAP clinical report, Pediatrics 2020;145(1):e20193449, doi:10.1542/peds.2019-3449, PMID 31843861; abstract). Checked October 23, 2026.
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   “Developmental surveillance is supported at every health supervision visit, as is as the administration of standardized screening tests at the 9-, 18-, and 30-month visits.”; “Developmental concerns elicited on surveillance at any visit should be followed by standardized developmental screening testing or direct referral to intervention and specialty medical care.”; “Developmental surveillance includes bidirectional communication with early childhood professionals in child care, preschools, Head Start, and other programs, including home visitation and parenting, particularly around developmental screening.”.
6. Hyman SL, Levy SE, Myers SM; AAP Council on Children With Disabilities, Section on Developmental and Behavioral Pediatrics. Identification, Evaluation, and Management of Children With Autism Spectrum Disorder (AAP clinical report, Pediatrics 2020;145(1):e20193447, doi:10.1542/peds.2019-3447, PMID 31843864; abstract). Checked October 23, 2026.
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   “Standardized screening for ASD at 18 and 24 months of age with ongoing developmental surveillance continues to be recommended in primary care (although it may be performed in other settings)”.
7. Centers for Disease Control and Prevention, Learn the Signs. Act Early. Key Points about CDC’s Developmental Milestone Checklists (page dated February 16, 2026). Checked October 23, 2026.
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   “CDC’s developmental milestone checklists are communication tools intended to encourage ongoing conversations between families and professionals.”; “The developmental milestones included on CDC’s milestone checklists are not developmental guidelines or standards for children’s development. They should not be used as screening or diagnostic tools to detect developmental delays.”; “CDC’s developmental milestones should not be used to establish medical necessity for the initiation or continuation of services.”; “Milestones were placed at ages by which at least 75% of children would be expected to exhibit them”; “CDC’s milestone checklists do not contain all possible milestones children might exhibit.”.
8. American Academy of Pediatrics, HealthyChildren.org. How to Keep Your Sleeping Baby Safe: AAP Policy Explained (parent page by Rachel Y. Moon, MD, FAAP, last updated September 11, 2026). Checked October 23, 2026.
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   “Place your baby on their back for all naps & at night.”; “Place your baby in a crib, bassinet, portable crib or play yard that meets the safety standards of the Consumer Product Safety Commission (CPSC).”; “Use a fitted sheet only—nothing else should be in the crib with your baby.”; “If your baby falls asleep in a car seat, stroller, swing, infant carrier or sling, you should move them to a firm sleep surface on their back as soon as possible.”; “Don’t use products for sleep that aren’t specifically marketed for infant sleep. Examples include Boppy pillows and Dock-a-Tots.”; “Instead of sharing a bed, share a room with your baby for at least the first 6 months of life.”; “Don’t use weighted blankets, sleepers, swaddles or other weighted objects on or near your baby.”; “Even babies with gastroesophageal reflux disease (GERD) should sleep flat on their backs.”; “Don’t use home cardiorespiratory monitors as a way to reduce the risk of SIDS.”; “Don’t hesitate to talk with your pediatrician if you have any questions or concerns about the safety of your baby’s sleep environment.”.
9. American Academy of Pediatrics, HealthyChildren.org. Back to Sleep, Tummy to Play: Give Your Baby a Safe, Strong Start (parent page adapted from Back to Sleep, Tummy to Play, last updated September 8, 2026). Checked October 23, 2026.
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   “Tummy time is for babies who are awake and being closely supervised.”; “Play and interact with your baby while they are awake and on their tummy 2 to 3 times each day for a short time (3 to 5 minutes).”; “You can start doing tummy time the day your baby gets home from the hospital.”; “Work up to 15 to 30 minutes each day by 7 weeks.”; “Limit time spent in freestanding swings, bouncy chairs and car seats.”.
10. Centers for Medicare & Medicaid Services. Calendar Year (CY) 2024 Medicare Physician Fee Schedule Final Rule (CMS fact sheet, section on caregiver training services). Checked October 23, 2026.
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    “Medicare will pay for these services when furnished by a physician or a non-physician practitioner (nurse practitioners, clinical nurse specialists, certified nurse-midwives, physician assistants, and clinical psychologists) or therapist (physical therapist, occupational therapist, or speech language pathologist) as part of the patient’s individualized treatment plan or therapy plan of care.”.
11. Federal Trade Commission. Advertising FAQ’s: A Guide for Small Business (FTC business guidance). Checked October 23, 2026.
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    “Advertising must be truthful and non-deceptive;”; “Advertisers must have evidence to back up their claims;”; “In most cases, ads that make health or safety claims must be supported by "competent and reliable scientific evidence"”; “Statements from satisfied customers usually are not sufficient to support a health or safety claim or any other claim that requires objective evaluation.”.
12. American Speech-Language-Hearing Association. Code of Ethics (effective March 1, 2023). Checked October 23, 2026.
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    “Individuals shall provide all clinical services and scientific activities competently.”; “Individuals shall obtain informed consent from the persons they serve about the nature and possible risks and effects of services provided, technology employed, and products dispensed.”; “Individuals may make a reasonable statement of prognosis, but they shall not guarantee—directly or by implication—the results of any treatment or procedure.”; “Individuals’ statements to the public shall adhere to prevailing professional standards and shall not contain misrepresentations when advertising, announcing, or promoting their professional services, products, or research.”.
13. eCFR, 16 CFR 461.2. Impersonation of government prohibited (FTC Rule on Impersonation of Government and Businesses, current as of October 2026). “It is a violation of this part, and an unfair or deceptive act or practice to:”; “materially misrepresent, directly or by implication, affiliation with, including endorsement or sponsorship by, a government entity or officer thereof”. Checked October 23, 2026.
14. eCFR, 34 CFR 303.21. Infant or toddler with a disability (IDEA Part C regulation, current as of October 22, 2026). Checked October 23, 2026.
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    “Infant or toddler with a disability means an individual under three years of age who needs early intervention services because the individual— (1) Is experiencing a developmental delay, as measured by appropriate diagnostic instruments and procedures”; “(2) Has a diagnosed physical or mental condition that— (i) Has a high probability of resulting in developmental delay”; “Infant or toddler with a disability may include, at a State’s discretion, an at-risk infant or toddler”.
15. Centers for Disease Control and Prevention, Learn the Signs. Act Early. Early Intervention (page dated February 17, 2026). Checked October 23, 2026.
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    “Early intervention is the term used to describe services and supports available to babies and young children with developmental delays and disabilities and their families.”; “Eligibility for early intervention services is based on an evaluation of your child’s skills.”; “Each state, territory, or commonwealth has its own early intervention program and rules about eligibility and services.”; “These publicly funded programs provide services for free or at reduced cost for any child who is eligible.”; “A doctor’s referral is not necessary.”.
16. Centers for Medicare & Medicaid Services. What is a good faith estimate? (CMS page for patients). “Usually, if you aren’t using health insurance to pay for your care, your health care provider must give you a good faith estimate of expected charges if you request one or schedule services at least 3 business days in advance.”. Checked October 23, 2026.
17. eCFR, 34 CFR 303.420. Parental consent and ability to decline services (IDEA Part C regulation, current as of October 22, 2026). Checked October 23, 2026.
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    “Determine whether they, their infant or toddler with a disability, or other family members will accept or decline any early intervention service under this part at any time, in accordance with State law; and (2) May decline a service after first accepting it, without jeopardizing other early intervention services under this part.”.
18. eCFR, 34 CFR 303.12. Early intervention service provider (IDEA Part C regulation, current as of October 22, 2026). “Early intervention service provider or EIS provider means an entity (whether public, private, or nonprofit) or an individual that provides early intervention services under part C of the Act”. Checked October 23, 2026.
19. American Academy of Pediatrics, HealthyChildren.org. Corrected Age for Preemies (parent page adapted from Understanding the NICU, last updated December 10, 2018). “During the first 2 years, using your baby’s corrected age will give you a better idea when he or she should reach common developmental goals.”. Checked October 23, 2026.
20. APTA Academy of Pediatric Physical Therapy. Comparison of Early Intervention and Hospital/Clinic-Based Physical Therapy Services (member-produced fact sheet, 2020). “In states with direct access, physician referral is not required for provision of physical therapy services but may be needed for reimbursement.”; “Provide episodes of care with clear entry, exit and reentry criteria.”. Checked October 23, 2026.
21. APTA Academy of Pediatric Physical Therapy. Interventions for Non-Synostotic Cranial Deformities in Infants including Plagiocephaly (member-produced fact sheet, revised June 17, 2020). Checked October 23, 2026.
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    “An abnormal head shape continuing beyond 6 weeks of age should be evaluated by a physician.”; “(Infants 0 – 4 months of age without torticollis, developmental concerns, or obvious skull deformities) Parent Education, Repositioning, and Exercises”; “Request referral for physical therapy or cranial remolding orthosis evaluations, if the infant demonstrates resistance to repositioning, neck tightness, movement asymmetries, or if the head shape worsens or does not improve with the repositioning and exercises.”; “Restricted neck and shoulder range of motion”; “Lack of head shape improvement after 1 month of caregiver repositioning/handling/tummy time”.
22. American Physical Therapy Association. Code of Ethics for the Physical Therapist (HOD S06-20-28-25). Checked October 23, 2026.
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    “2C. Physical therapists shall provide the information necessary to allow patients or their surrogates to make informed decisions about physical therapist care or participation in clinical research.”; “4A. Physical therapists shall provide truthful, accurate, and relevant information and shall not make misleading representations.”; “6A. Physical therapists shall achieve and maintain professional competence.”.
23. American Occupational Therapy Association. AOTA Occupational Therapy Code of Ethics: Core Values and Principles (AOTA infographic on the Code of Ethics, copyright 2025, linked from AOTA’s ethics page beside the AOTA 2025 Occupational Therapy Code of Ethics; its guiding ethical principles are shown as Beneficence, Non-maleficence, Autonomy, Justice, Veracity and Fidelity). Checked October 23, 2026.
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    “Core values are aspirational targets and the guiding principles aid in ethical decision-making.”; “Sanctionable offenses and violations of ethical standards are addressed separately under the Code’s Standards of Conduct, which outline specific and enforceable behaviors.”.
24. Medicaid.gov, Centers for Medicare & Medicaid Services. Early and Periodic Screening, Diagnostic, and Treatment (CMS benefit page). Checked October 23, 2026.
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    “The Early and Periodic Screening, Diagnostic and Treatment (EPSDT) benefit provides comprehensive and preventive health care services for children under age 21 who are enrolled in Medicaid.”; “States are required to furnish all 1905(a) Medicaid coverable, appropriate, and medically necessary services needed to correct and ameliorate health conditions, based on certain federal guidelines.”.
25. eCFR, 42 CFR 440.110. Physical therapy, occupational therapy, and services for individuals with speech, hearing, and language disorders (federal Medicaid regulation). Checked October 23, 2026.
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    “Physical therapy means services prescribed by a physician or other licensed practitioner of the healing arts within the scope of his or her practice under State law”; “Occupational therapy means services prescribed by a physician or other licensed practitioner of the healing arts”; “for which a patient is referred by a physician or other licensed practitioner of the healing arts within the scope of his or her practice under State law.”.
26. American Physical Therapy Association. Levels of Patient Access to Physical Therapists Services in the U.S. (APTA resource dated September 4, 2024). “While all 50 states, the District of Columbia and the U.S. Virgin Islands, provide some form of direct access to physical therapist services, the specific provisions and limitations differ across jurisdictions.”. Checked October 23, 2026.
27. Centers for Disease Control and Prevention, Learn the Signs. Act Early. Developmental Monitoring and Screening (page dated February 17, 2026). Checked October 23, 2026.
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    “Parents, grandparents, early childhood providers, and other caregivers can participate in developmental monitoring.”; “The tools used for developmental screening are formal questionnaires or checklists based on research that ask questions about a child’s development, including language, movement, thinking, behavior, and emotions.”; “The American Academy of Pediatrics (AAP) recommends developmental screening for all children during regular well-child visits at least at these ages”; “If your child’s healthcare provider does not periodically check your child with a developmental screening test, you can ask them to do so.”; “HOW: With easy-to-use, free checklists”; “Healthcare providers, and anyone who works with young children, can refer families to early intervention for assessment. Families can also refer themselves directly.”.
28. Communication Health Support Association, the consumer site ASHA’s page redirects to. Tips for Your Child’s Speech and Language Development (consumer page for the public). Checked October 23, 2026.
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    “Look at your baby when they make sounds. Talk back to them and repeat what they say.”; “Use gestures, like waving and pointing.”; “Talk about what you are doing. Talk to your baby as you give them a bath, feed them, and get them dressed.”; “Talk, sing, play, read, and listen together in any of the languages that you and your child use.”.
29. Moon RY, Carlin RF, Hand I; AAP Task Force on Sudden Infant Death Syndrome and Committee on Fetus and Newborn. Sleep-Related Infant Deaths: Updated 2022 Recommendations for Reducing Infant Deaths in the Sleep Environment (AAP policy statement, Pediatrics 2022;150(1):e2022057990, doi:10.1542/peds.2022-057990, PMID 35726558; abstract). Checked October 23, 2026.
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    “This includes supine positioning; use of a firm, noninclined sleep surface; room sharing without bed sharing; and avoidance of soft bedding and overheating.”; “New recommendations are presented regarding noninclined sleep surfaces, short-term emergency sleep locations, use of cardboard boxes as a sleep location, bed sharing, substance use, home cardiorespiratory monitors, and tummy time.”.
30. Centers for Disease Control and Prevention, Learn the Signs. Act Early. Concerned About Your Child’s Development? (page dated February 17, 2026). Checked October 23, 2026.
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    “Note: these checklists are not a substitute for standardized, validated developmental screening tools.”; “At the same time as you ask the doctor for a referral to a specialist, call your state’s public early childhood system to request a free evaluation to find out if your child qualifies for intervention services.”; “You do not need to wait for a doctor’s referral or a medical diagnosis to make this call.”.
31. American Speech-Language-Hearing Association. Medicare CPT Coding Rules for Speech-Language Pathology Services (ASHA reimbursement page listing CPT descriptors). Checked October 23, 2026.
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    “Caregiver training in strategies and techniques to facilitate the patient’s functional performance in the home or community”; “(without the patient present), face to face; initial 30 minutes”; “Group caregiver training in strategies and techniques to facilitate the patient’s functional performance in the home or community”; “(without the patient present), face to face with multiple sets of caregivers”.
32. eCFR, 34 CFR 303.303. Referral procedures (IDEA Part C regulation, current as of October 22, 2026). “Provide for referring a child as soon as possible, but in no case more than seven days, after the child has been identified”; “(8) Other clinics and health care providers;”. Checked October 23, 2026.
33. HHS Office of Inspector General. Policy Statement Regarding Gifts of Nominal Value To Medicare and Medicaid Beneficiaries (policy statement, December 7, 2016). Checked October 23, 2026.
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    “the statute defines "remuneration" to include, without limitation, waivers of copayments and deductible amounts (or any part thereof) and transfers of items or services for free or for other than fair market value.”; “any remuneration that the person knows or should know is likely to influence the beneficiary’s selection of a particular provider, practitioner, or supplier of Medicare or Medicaid payable items or services may be liable for civil monetary penalties”.
34. APTA Academy of Pediatric Physical Therapy. Early Intervention Physical Therapy: IDEA Part C (member-produced fact sheet, 2010). Checked October 23, 2026.
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    “Physical therapists use their knowledge and skills specifically related to motor and self-care function, assistive technology, and medical/ health care science to provide a unique contribution to the IFSP team.”; “Physical therapists provide service by collaborating with the team, exchanging information with the family, and integrating interventions into everyday routines, activities, and locations.”.
35. American Occupational Therapy Association. Early Intervention (AOTA practice-setting page). “Occupational therapy practitioners provide early intervention services to support the development and learning of babies and young children with developmental delays and disabilities and their families.”. Checked October 23, 2026.
36. Clark GF, Kingsley KL. Occupational Therapy Practice Guidelines for Early Childhood: Birth-5 Years (AOTA practice guideline, Am J Occup Ther 2020;74(3):7403397010, doi:10.5014/ajot.2020.743001, PMID 32365324; abstract). Checked October 23, 2026.
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    “A variety of interventions within the domain of occupational therapy were found to support the development of cognitive, social-emotional, motor, and self-care skills.”; “Although some of these interventions are typically implemented by occupational therapy practitioners, others can be implemented by parents after training or by teams working in preschool settings.”.
37. American Speech-Language-Hearing Association. Pediatric Feeding and Swallowing (ASHA Practice Portal clinical topic). Checked October 23, 2026.
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    “Speech-language pathologists (SLPs) are the preferred providers of dysphagia services and are integral members of an interprofessional team.”; “The clinical evaluation for infants from birth to 1 year of age includes an evaluation of prefeeding skills, an assessment of readiness for oral feeding, an evaluation of breastfeeding/chestfeeding and bottle-feeding ability, and observations of caregivers feeding the child.”; “a lactation consultant (infants);”.
38. American Occupational Therapy Association. Occupational therapy and feeding, eating, and swallowing (AOTA clinical topic page). “Occupational therapy practitioners play a crucial role in addressing feeding, eating, and swallowing challenges for clients across the lifespan.”; “Occupational Therapy interventions support the skills needed for safe and effective eating and swallowing.”. Checked October 23, 2026.
39. U.S. Department of Health and Human Services, Office for Civil Rights. Personal Representatives (HIPAA guidance, content last reviewed January 5, 2024). Checked October 23, 2026.
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    “In most cases under the Rule, a parent, guardian, or other person acting in loco parentis (collectively, "parent") is the personal representative of the minor child and can exercise the minor’s rights with respect to protected health information, because the parent usually has the authority to make health care decisions about his or her minor child.”.
40. U.S. Department of Health and Human Services, Office for Civil Rights. Covered Entities and Business Associates (HIPAA guidance, content last reviewed August 21, 2024). Checked October 23, 2026.
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    “If an entity does not meet the definition of a covered entity or business associate, it does not have to comply with the HIPAA Rules.”; “but only if they transmit any information in an electronic form in connection with a transaction for which HHS has adopted a standard.”.
41. eCFR, 45 CFR 160.103. Definitions (HIPAA general provisions). Checked October 23, 2026.
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    “Individually identifiable health information is information that is a subset of health information, including demographic information collected from an individual, and: (1) Is created or received by a health care provider, health plan, employer, or health care clearinghouse; and (2) Relates to the past, present, or future physical or mental health or condition of an individual”; “Protected health information means individually identifiable health information:”.
42. U.S. Department of Health and Human Services, Office for Civil Rights. May mental health practitioners or other specialists provide therapy to patients in a group setting where other patients and family members are present? (HIPAA FAQ, content last reviewed January 9, 2023). Checked October 23, 2026.
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    “Disclosures of protected health information in a group therapy setting are treatment disclosures and, thus, may be made without an individual’s authorization.”; “Absent countervailing circumstances, the individual’s agreement to participate in group therapy or family discussions is a good basis for inferring the individual’s agreement.”.
43. eCFR, 45 CFR 164.508. Uses and disclosures for which an authorization is required (HIPAA Privacy Rule). “Except as otherwise permitted or required by this subchapter, a covered entity may not use or disclose protected health information without an authorization that is valid under this section.”. Checked October 23, 2026.
44. Federal Trade Commission. Health Products Compliance Guidance (FTC staff guidance, December 2022). Checked October 23, 2026.
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    “FTC law focuses not on the marketer’s intent, but on the consumer’s understanding.”; “marketers shouldn’t focus narrowly on individual phrases or statements, but rather should consider each ad as a whole, assessing the "net impression" conveyed by all elements of the ad, including the text, product name, and any charts, graphs, and other images.”; “FTC advertising law applies to all products and claims.”.

Medical disclaimer. This page is for general educational purposes and does not constitute medical advice, diagnosis, or treatment. It is general guidance on running a therapy practice, not legal, compliance, billing or financial advice. It gives no clinical advice about any baby, and early intervention and payer rules differ by state, so confirm them with your state’s lead agency and each payer.