Principal Issues: (i) Whether teachers and daycare providers would be considered primary caregivers for purposes of paragraph 118.3(1.1)(c)? and
(ii) Would time spent educating teachers and daycare providers be considered time spent administering therapy?
Position: (i) Generally, no.
Reasons: (i) A teacher or daycare provider would not likely be considered a child's primary caregiver as required by paragraph 118.3(1.1).
(ii) Time spent educating individuals, such as teachers and daycare providers would not be considered as time spent receiving therapy, and would therefore be excluded.