As the School Nurse Coordinator for our division and on behalf of our nurses,   I strongly oppose the the proposed changes in the school-based  Medicaid reimbursement program.  I have participated in Medicaid Billing with students for the past eight  years and  am speaking to the practical application of these proposals. I am addressing them based on my opinion that the RN is highly qualified to develop  strong, evidence-based Plans of Care for  students  without  the need for review and signature of the physician.  She sees the students daily;  she knows the goals that need to be established for the student to be compliant with physician's orders.  

The current process is cumbersome and requires strict attention to detail with no room for error.   If the school nurse is billing for multiple students, this is not easily accomplished during a school day without  compromising  student health care needs.  The nurse often completes this work beyond school hours.   If these new proposals are approved and implemented,  they will result in a further increase in time to create, track, process and complete required paperwork, utilizing the same narrow criteria, for each student.  The nurse may end up being forced to choose between taking time away from student care,  using even more of her personal time after school, or refusing to participate, none of which are good options for the student, the nurse, or the school division. 

The requirement of physician review and signature on a Plan of Care will result in a loss of  billable services revenue as the nurse has no control over the willingness  or the efforts of the physician/office staff to comply with requests in a timely manner.

If multiple physicians are ordering services for one student, the nurse will have to track this process with each physician  which is overwhelming in and of itself.   Added to this is the loss of  exponentially increased billing services revenue because of wait time.  If the nurse has multiple students with multiple physicians,  the process can quickly become unsustainable.  Her capability to provide high quality student health care utilizing best practices will be significantly impacted.  Something will have to give and it should never, ever be student care.  To place her in this position is  unfair and unreasonable, and undermines her work as a professional school nurse.

I urge you to reconsider these proposals and allow the current school-based Medicaid reimbursement program to remain in place.