We oppose the proposed changes by DMAS to the Medicaid reimbursement program.  Specifically, requiring a physician's order for personal care assistance with daily living supervised by an RN and then requiring a physician to sign the plan of care (POC) once created (for both personal care and nursing), are time consuming and potentially will not be completed by the physician.  The physician has no accountability to sign the Plan of Care as it will not affect them in any way.  Also, who is responsible for any potential fees charged by the physician for signing off on the plan of care?  The time spent having the POC signed (if the physician does sign it) will count against us for the billing compliance review because any services delivered before the POC is signed will count as delivered services not billed.  The lower compliance percentage will decrease our cost reimbursement amount as well.  

The potential reduction in Medicaid reimbursement amounts is troubling when these reimbursements are used to help provide special education services.  Federal, state and local education funding isn't able to keep pace with the cost of providing special education, and as this funding decreases, the reliance on Medicaid reimbursement to off-set special ed cost increases becomes more and more important.  

The additional administrative time needed to obtain the necessary paperwork and signatures is also troublesome.  Several POCs would also need to be signed if a student was seen by multiple physicians/specialists (ex. if a student was diagnosed with diabetes, ADHD and had tube feedings), which would then increase the number of claims as each POC would have to be submitted on a different claim with each physician NPI number.  DMAS qualified providers and other employees currently have full workloads, and these proposed changes would require additional time to complete all of the DMAS requirements.

Please work to find another solution and do not implement these proposed changes.