Arlington Public Schools opposes the proposed changes by the Department of Medical Assistance Services (DMAS) to the Virginia school-based Medicaid reimbursement program.  Specifically, the proposed changes that would require a physician’s signature for each Plan of Care for nursing and personal care services could force school divisions to discontinue billing for these services.  At best, these changes would create a significant amount of additional work and cost for local school divisions.  The requirement for a physician’s signature for each Plan of Care may be difficult to obtain, and will likely result in a decrease in reimbursement for these services.  In addition, complications of billing for nursing and personal care services could impact school divisions’ transportation reimbursement, since billing for transportation depends on other billable services. 

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 will result in services being given and not billed for in turn affecting 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 multiple doctors with multiple orders could result in excessive paperwork in tracking the time of administering medication/nursing services per each doctor.  How do we know that the ordering physician is a registered ORP especially with the urgent care facilities?

A decrease in Medicaid reimbursement  dollars and an additional cost to school divisions for participating in the Medicaid reimbursement program is of great concern.  As the number of students with disabilities increased (by 24% in Virginia in the past four years), so did the complexities of students’ needs.  Consequently, federal, state, and local education funding fails to keep pace with the cost of providing special education, causing school divisions to rely more and more on Medicaid reimbursement to off-set the increasing costs of specialized instruction and related services. 

We urge you to reconsider these proposed changes and allow the current school-based Medicaid reimbursement program requirements to remain in place. 

The proposed changes will impede APS from seeking reimbursement for nursing, personal care and transportation.  The additional revenue would help APS offset the cost of providing the IEP services, which will in turn would provide better resources to make the student(s) successful.