On behalf of Fairfax County Public Schools (FCPS) and the Fairfax County Health Department (FCHD) that is responsible for the administration of contracted one-on-one nursing services for medically fragile students enrolled in FCPS; we would like to express our serious concerns and opposition to the recently proposed changes in documentation requirements for nursing and personal care services. Requiring each physician treating a student to sign a separate Plan of Care and requiring separate claims be submitted per ordering physician for nursing and personal care services would have a significant adverse impact on our Medicaid reimbursement program.
FCPS is the largest school system in the Commonwealth of Virginia and the 10th largest school district in the nation. Families of students with complex medically fragile conditions often choose to enroll in our school system due to the availability of high caliber educational and health services. The reimbursements received through the Virginia Medicaid and Schools program strengthen our district’s ability to provide mandated special education programs for the increasingly complex needs of our students with disabilities.
With limited federal funding to support the differentiated needs of over 27,000 students with disabilities identified under the Individuals with Disabilities Act (IDEA), FCPS relies partly on Medicaid reimbursements to support students with special needs. The proposed changes in nursing and personal care service documentation would increase the administrative workload, thus requiring increased staffing and resources to ensure our compliance, and potentially reducing our ability to implement the programming that we have historically been able to provide in part through Medicaid reimbursements. The costs of coordinating and managing the additionally required paperwork could easily outweigh any reimbursement we receive. Requiring a physician’s signature for each Plan of Care would be inefficient and problematic, especially when there are multiple medical specialists involved as is the case for medically fragile children. A review shows that our current students with nursing services have an average of 3 to 4 specialist physicians involved. The proposed process could lead to more fragmented care rather than the current coordinated holistic approach to supporting students with complex health conditions in which one Plan of Care becomes the comprehensive plan to meet that student’s needs. In the current model the primary care physician is the closest to the child and has reviewed and endorsed the specialist’s recommendations for an integrated care approach for the child. We also believe one integrated Plan of Care provides safer care for the child in the school setting as the nurse has one guiding care document that has been reviewed to ensure there are no conflicts in care. If a Plan of Care is developed for each specialist separately and each specialist is required to sign his or her own Plan of Care, essentially in silos, there is a greater potential for uncoordinated and unsafe care in the school setting.
Vendors who contract with Fairfax County to provide nursing services within our school division have also expressed their concern regarding the possible difficulty with meeting the proposed requirements. They have indicated that these proposed changes pose a hardship on school divisions that may result in fragmented care for the students along with a need for requiring additional vendor resources. As a school and public health system, we fear that the potential for future vendor support may wane as vendors will find it too expensive and resource/time intensive for them to bid on our contracts. Thus, these changes may limit our ability to find vendors, may increase the cost to obtain vendors in the future, and will result in increased administrative burden at all levels—school system, health department and nursing agencies. The cost-benefit of these proposed changes at the local level need to be considered.
On behalf of Fairfax County students, staff, and families, we urge you to reconsider your proposed changes and allow the current requirements to remain in place to ensure school systems are able to continue providing support to our most vulnerable students.