As a local special education director, I am very concerned about the proposed changes to the Virginia school-based Medicaid billing program.  Specifically, the requirement for 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, this change could create additional paperwork and cost for local school divisions.  A physician's signature for each Plan of Care could be significantly difficult to obtain and will likely cause a decrease in reimbursement for these services.  In addition, complications with billing for nursing and personal care services could jeopardize reimbursement for transportation services since reimbursement for transportation is dependent on other billable services.  

The potential of a decrease in Medicaid reimbursement dollars is of great concern to me in my division.  As the number of students with disabilities increases and the complexities of meeting these disability-related needs increase as well, federal, state, and local funding has failed to keep pace with the increased costs of educating students with disabilities.   My division relies more and more on Medicaid reimbursement funds to supplement the cost of specialized instruction and related services.  

I urge you to reject the proposed changes and keep the current Medicaid procedures in place.  

Thank you.