As a nursing supervisor for Chesterfield County Public Schools and a VDOE Medicaid in Schools Conference Presenter, I would like to express my concerns over the proposed changes to the Virginia school based Medicaid Reimbursement program. Specifically, the proposed changes that would require a Licensed Healthcare Provider's (LHP) signature for each Plan of Care for nursing and personal care services and that separate claims be submitted per ordering LHP.

The proposed requirements would unnecessarily place additional administrative time demands on our nurses, which ultimately results in lost time caring for our students. Currently, an RN, as a professional school nurse, creates a comprehensive Plan of Care based on their nursing assessment and written LHP orders, as is in their scope of practice. It would be redundant to send the Plan of Care back to the prescriber for an additional signature when they have already provided their signature on the original order. Many of our students see multiple providers and the request to write separate Plans of Care for each provider and track their return is inefficient and time consuming. Additionally, these steps will need to be repeated with every amendment to the order and many physician offices charge a fee to complete paperwork. Who will incur these costs? The families? The school division? Is the medical community aware of the additional requirements they are being asked to provide? It is already challenging to get necessary paperwork and orders from LHPs and there is no incentive for them to comply with the new proposed requirements to sign and return the documentation.

The requirement to have the LHP signature on the Plan of Care will result in a loss of billable service revenue, as the nurse has no control over the willingness or the efforts of the LHP to comply with requests in a timely manner. 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 increase (by 24% in Virginia over the past 4 years) so does the complexity of student needs. Consequently, the federal, state, and local funding fails to keep pace with the cost of providing special education services. Medicaid reimbursement funds are intended to be used to offset these costs.

The additional documentation that would be required for Plans of Care and documenting service claims per individual prescriber, provides no additional benefits or services to our students. These proposed changes would result in decreased reimbursement and valuable time spent away from caring for students, keeping them safe, healthy, and ready to learn. 

I urge you to please reconsider these proposed changes.

Heather Snyder, BSN, RN, NCSN, CDDN