Good afternoon.  I am writing to express concern about the added layer of red tape proposed in this notice - a step that requires a doctor signature on a Plan of Care prior to our school division being able to seek reimbursement for nursing services through Medicaid.  This unnecessary and cumbersome step will likely result in significant loss in revenue and will do nothing to improve the care students receive.

Nurses author a Plan of Care based upon Doctor's orders to begin with, so I do not believe that that collaborative step needs to be replicated. 

Please consider addressing whatever the catalyst was for this change in a way that doesn't result in such potential cost to the schools and students we serve.  

As a professional nurse, I have never been required to have a provider's authorization on a written care plan. Part of my responsibility to the patient, is that I will develop a plan of care with a goal(s), provide care, then measure if the goal was met. Virginia will not mandate nurses in our schools but who is going to complete all of these requirements for Medicaid billing if we aren't here to do it? This would consume additional time that would be taken from providing nursing care and supervision. Our children are ensured the ability to attend school and be provided with the safest and most optimal setting. Consuming time by shuffling unnecessary paperwork will not allow us to provide what we are promising. 

As the Medicaid Coordinator for Galax City Public Schools, I oppose the changes that DMAS is proposing to the Medicaid reimbursement program.  Requirement of a physician's signature for each Plan of Care for nursing and personal care services would be detrimental to Galax in that the turnaround time would be too great in relation to Medicaid billing ability.  Funding that is received from Medicaid helps to offset the rising cost of services and programs that we provide to our students.  

Hopefully these proposed changes will be reconsidered and the reimbursement program will be allowed to stay the same.

We, the members of the Virginia Association for Behavior Analysis (VABA) Public Policy Committee sincerely urge you to add Applied Behavior Analysis (ABA) as a covered service under Medicaid.  Currently, ABA is covered by EPSDT under the Behavioral Therapy umbrella, however, the constraints that program places do not allow Virginia Medicaid recipients to fully benefit. 

ABA is not a treatment directed solely at children or a specific diagnosis.  Rather it is the application of the science of behavior, which encompasses all ages and transcends diagnosis.  ABA has a large body of research under the heading Applied Behavior Analysis, but also using names of treatment modalities, such as contingency management, positive reinforcement, stimulus equivalence, and shaping, just to name a few.  For more information on behavior analysis, research, and application, see https://www.bacb.com/about-behavior-analysis/ and https://www.bacb.com/about-behavior-analysis/applied-behavior-analysis/. 

The American Psychological Association (APA) and the American Medical Association (AMA) have recognized the rigor of ABA as treatment and the AMA recently (2019) released Category 1 CPT codes for ABA that apply regardless of diagnosis.

In Virginia, there are currently over 1200 persons licensed in behavior analysis and the field is growing.  Adding ABA as a covered service would increase the qualified and professional workforce available to serve Virginians with Medicaid at a time when some have difficult finding treatment in a timely manner. 

I am a school nurse  and I oppose the proposed changes by the Department of Medical Assistance Services to the Virginia school based Medicaid Care reimbursement program. The proposed changes requiring a physician's signature for each plan of care will be difficult and very time consuming to obtain. This requirement creates a burden on the school system as well as the physician's practices. Many physicians' offices now charge a fee for paperwork completion which could result in a cost to our families or a reduction in the amount of monies we are reimbursed. It is not required to have a physician's signature for a nursing care plan in a hospital setting. Requiring a physician's signature for a school nurse's care plan is beyond the normal standard..

The number of students with disabilities has increased significantly over the years as well as the student needs. Federal, state and local funding is not able to keep up with the cost of providing Special Education needs and has resulted in school divisions relying on Medicaid reimbursements. The children that benefit form this program require special equipment,  transportation, and individualized care in order to participate in Public Education. The extra time and resources required by the proposed changes could result in a decrease in school participation in this program. The monies our schools would lose will adversely affect services to our students with special needs.

I urge that the current school-based Medicaid reimbursement program requirements stay the same.

Manual: 'All Manuals'

Chapter I, General Information

Covered Services: The following services are provided, with limitations (certain of these limitations are set forth below), by the VA Medicaid Program: - Hearing services  -Speech-language therapy services.

CONCERN: Specifies limitations, yet only indicates that certain, not all, limitations are set forth below....

Telemedicine for selected services - limited to certain types of providers.

CONCERN: Indicates limitations, yet does not specify which type of provider.

Manual 'Local Education Agency Provider Manual' Chapter VI, Utilization Review and Control, Services-Specific Documentation Requirements

-Well Child Visits/EPSDT Screenings and Medical Evaluations   -In Addition to the general documentation requirements stated previously in this chapter, the record must include the following: ...-Referrals, including the name of the referring physician, nurse practitioner or PA...

CONCERN: Referrals from an MD, NP, or PA would be required for audiological and speech-language pathology evaluations.