Dear Department of Medical Assistance Services,

I am writing as chair of the Virginia Council of Administrators of Special Education (VCASE) Policy and Legislative Committee.  I am opposed to the proposed changes by the Department of Medical Assistance Services (DMAS) to the Virginia school-based Medicaid reimbursement program.

The proposed changes that would require 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, these changes would create a significant amount of additional work and cost for local school divisions. The requirement for a physician’s signature for each Plan of Care may be difficult to obtain, and will likely result in a decrease in reimbursement for these services.  In addition, complications of billing for nursing and personal care services could impact school divisions’ transportation reimbursement, since billing for transportation depends on other billable services.  

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 increased (by 24% in Virginia in the past four years), so did the complexities of students’ needs.  Consequently, federal, state, and local education funding fails to keep pace with the cost of providing special education, causing school divisions to rely more and more on Medicaid reimbursement to  off-set the increasing costs of specialized instruction and related services.

In addition to the substantive concerns above, I am very concerned that the unexpected, late, and terribly timed notice, on August 29, 2019 (the Thursday before the Labor Day weekend and the start of the school year for many divisions) to local school division leaders and special education directors, impaired their ability to discern the magnitude and impact of these proposals and respond in such short notice by September 22, 2019.

I urge you to reconsider these proposed changes and allow the current school-based Medicaid reimbursement program requirements to remain in place.  More discussion among superintendents, division finance directors, special education administrators, and DMAS is needed before such sweeping changes are implemented that significantly hurt local school divisions’ efforts to fund these mandated special education services.

Sincerely,

Mike Asip, Ed.D.