Harrisonburg City Public Schools opposes the proposed changes by DMAS to the Virginia school-based Medicaid reimbursement program.  Having to have the Nursing Plan of Care signed by the physician will cause extra work and loss of revenue for school divisions and the State.  The signing of the Plan of Care by the Physician unfortunately will not be a top priority for the physician which will result in services being given and not billed for in turn affecting the cost report, interim billing, Billing Compliance Review, and Administrative Activity Claiming.  Doctors generally charge for filling out forms.   Who will be responsible for these charges?  This could result in the parent revoking permission for billing of Medicaid.  One student with multiple doctors' orders could result in excessive paperwork in tracking the time of administering nursing services for each doctor.

Potential financial obligations for the school division when the doctor signs order for personal care, communicates this to the parent, and parent expects the school to have it implemented in the IEP (one on one).  The concerns in regards to the nursing Plan of Care will have the same affect on Personal care as well.

A decrease in Medicaid reimbursement dollars and additional cost to school divisions for participating in the Medicaid reimbursement program is of great concern.  The number of students with disabilities has increased significantly over the years as well as complexities of students' needs.  As federal, state, and local education funding is not able to keep pace with the cost of providing special education resulting in school divisions to rely more on the Medicaid reimbursement to off-set the increasing costs.

The proposed changes to the manual do not provide clarification or guidance for psych, nursing, personal care, and transportation.

Time and services used to track all of this paperwork will affect the monies that would be used to benefit the students could ultimately result in school divisions discontinuing the billing of nursing, personal care, psych, and transportation.

The current school-based Medicaid reimbursement program requirements need to remain in place.