The current, proposed changes to the DMAS LEA Provider Manual include changes to requirements that will have a negative impact on LEAs ability to bill for nursing and personal care services.  This would also have a negative impact on LEA transportation billing.   Ultimately these could result in limited resources for and quality of school services.

Chapters IV and VI include proposed changes to Nursing services and Personal Care Assistance (PCA) services supervised by a Nurse that adds a requirement to the current process.  The changes would require the signature of the referring physician on the Plan of Care (POC) that is written by the school Nurse. This step would be a duplication of the Physicians original order, which the Nursing POC must be written to reflect.  

Specific concerns with the new process include:

• Students with multiple physicians and specialists could require multiple POCS signed by different physicians  

• Tracking the POC receipt, physician signature and return to the school

  • Schools have no guarantee that Physicians will sign and return the signed POC

  • Physician’s offices could impose a charge to schools for this additional requirement for them

• Each student may have multiple claims that need to be submitted to DMAS, one per referring provider.

  • Increase in paperwork and resources of School staff and DMAS staff

  • Currently DMAS only allows one Nursing service claim per month, per student.  Any more than one per month gets denied as a duplicate claim (even if it includes additional/different services and dates).  This process would not allow school divisions to get paid for multiple monthly claims, even though the changes will require multiple claims. 

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. I urge you to please reconsider these proposed changes and allow the current school-based Medicaid reimbursement program requirements to remain in place.

The other proposed change that I question is in Chapter IV, Physical Therapy section, bullet 5.  Why does Physical Therapy include the addition of the requirement for Short and Long Term Goals, while Occupational Therapy, Speech Language Therapy, Audiological Services and Psychiatry Psychology and Mental Health Services do not include this additional requirement?  There has been no practice change for Physical Therapists that would precipitate this specific requirement.