The proposed changes to Medicaid billing undermine the autonomy of the school nurse in assessing, planning, implementing, and evaluating outcomes of individualized student health care.  We only need a doctor to write the order.  

The proposed changes to the Medicaid billing undermine the autonomy of the school nurse in assessing, planning, implementing and evaluating outcomes of individualized student health care. We only need a doctor to write the order!

Several concerns over the proposed changes. 

1.  Accountability fro unsigned or delayed signing of plans of care.  This would impact the Self Audit and its effect on Cost Reimbursement.   I don't think you realize how difficult it is to get paperwork back in a timely manner from physicians if at all. 

2. Physicians may charge for signatures/paperwork.  Who would be responsible for these costs, division or parents?  

3.  If parents have to pay for paperwork, they may potentially decline or revoke consent and thus impact our cost reimbursement through our self audit/BCR. 

4.  With the proposed changes, the increased documentation requirements, increased work for staff to insure compliance and still with the potential loss of reimbursable funds for division we may not be able to bill for personal care and nursing or hire additional staff.  

5.  Personal care services do not require orders from a physician.  It does fall within the scope of nursing practice. 

My Biggest Concern is that I attended the proposed manual revision meetings and do not recall this coming up at the meeting. 

Shenandoah County Public Schools strongly opposes the proposed DMAS changes to the policy manual for nurses, personal care assistants, and psychological services.  We are heavily dependent on Medicaid reimbursements for meeting the needs of our most vulnerable population and in a community that is already under-served in terms of health related services. These proposed changes would impact funding to the school division due to loss of billable time waiting for the physician to sign and return the Plan of Care, potential doctor fees for completing additional paperwork, and loss of funding for transportation for these lost billable services.  These changes would also result in increased staff time in following up on the required information and tracking data for students who have multiple physicians that would result in a Plan of Care for each physician. School divisions would have to submit claims per physician.  If a student had asthma, diabetes, and tube feeding all ordered by different specialists, three claims would be submitted instead of one.  This would also be an additional cost to school divisions.  Nurses and Personal Care Assistants will be tracking more data, billing for possibly less services and will be taking time away from other students.  The proposed changes to psychology will also result in increased time tracking data and documentation.

We are opposed to the proposed DMAS changes.  For those who are "on the ground", working with children and parents, these changes will increase bureaucracy without improving services to students.  School staff, including nurses, have no control over doctors' offices timelines and willingness to review, sign and return Plans of Care.  While waiting on POCs to be signed and returned, the school division not only loses billable services but also bears the impact on its cost reimbursement.  It is unreasonable to school divisions to bear the fiscal consequences for a delayed/ unmet requirement that is beyond their control.

The proposed changes to the policy manual for nurses, personal care assistants and psychological services will significantly affect the funding our school division receives from DMAS for services provided.  These changes would impact funding to school divisions due to loss of billable time waiting for the physician to sign and return the Plan of Care, potential doctor fees for completing additional paperwork, and loss of funding for transportation for these lost billable services.  These changes would also result in increased staff time in following up on the new required information and tracking data for students who have multiple physicians that would result in a Plan of Care for each physician. School divisions would also have to submit a claim per physician which would be an additional cost to school divisions. 

As Director of Special Education in Alleghany County, I agree with VCASE opposition to the proposed changes by the Department of Medical Assistance Services (DMAS) to the Virginia school-based Medicaid reimbursement program.  Specifically, 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. 

As a rural school division 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. 

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

As a special education director in Virginia and a member of the Virginia Council of Administrators of Special Education (VCASE),  I oppose the proposed changes by the Department of Medical Assistance Services (DMAS) to the Virginia school-based Medicaid reimbursement program. Specifically, 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. I am also deeply concerned that the medical community is unaware of these proposed changes and the impact it will have on our ability to bill for 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. I urge you to please reconsider these proposed changes and allow the current school-based Medicaid reimbursement program requirements to remain in place.

Medicaid reimbursement has allowed our division to buy safety equipment, update clinic fixtures and medical supplies, and buy lifesaving medication, for our students. These items have allowed us to acquire an increased confidence that our students'safety needs are being met on our campuses.  Our skilled staff meets our students' daily needs for Activities for Daily living, and we are very keen to any changes of medical symptoms our students may present.  With accurate and daily documentation, we charge for our nursing services, and paraprofessional assistance.

The subdivision of ordering medical providers carriers new challenges. Our area is experiencing a down-sizing of care, due to a merger of two medical systems, to Ballad Health Care. Specialists are relocating, and small community hospitals are closing. Many of our special needs children are required to travel 60 to 400 miles, for specialized care.  Our local Level 1 trauma center is being downgraded to a Level III in 2 weeks. (This translates in to fewer specialists available.) Acquiring signatures of original documents will be laborious, for our staff and medical providers

Like most divisions, our frailest children have many barriers to receiving the health care they need. They may encounter dismissals and reassignments from insurance providers, and this matter can be confusing for parents and guardians. Transportation is a large barrier for our impoverished citizens, and many do not have cellular phone access to quickly request assistance.  

Our motto is, "Every Child, Every Opportunity". We will continue to provide for our students, but a large reduction in reimbursement funds, will have a ripple effect for all our students.

We are absolutely OPPOSED to these DMAS changes.  For those of us working directly with these children and their parents, these changes will increase bureaucracy without improving services to students.  We spent enough time with this paperwork, we do not need another step in this tedious process.  School nurses (Occupational Therapist, Physical Therapist, Speech, etc.)  have no control over Healthcare Providers timelines and willingness to review, sign and return our POC.  We are professional nurses, we can write and implement a POC without a Healthcare provider approving it. While waiting on POCs to be signed and returned, the school division not only loses billable services but also bears the impact on its cost reimbursement (or NO reimbursement).  It is unreasonable to school divisions to bear the fiscal consequences for a delayed/unmet requirement that is beyond our control. 

...a change that cuts on funds for school divisions affecting billing for medicaid,I absolutely opposed .There has been an increase in the number of students that have one or more medical conditions and therefore require special accomodations and services while in school. Children are the future of our society and any decrease in funds good affect a positive outcome.

I am also strongly opposed to the proposed Medicaid reimbursement changes. I agree with all of the comments made thus far, and see this change only adversely affecting the children it is meant to help. 

As a special education administrator, I oppose the proposed changes by the Department of Medical Assistance Services (DMAS) to the Virginia school-based Medicaid
reimbursement program. Specifically, 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.
We urge you to reconsider these proposed changes and allow the current
school-based Medicaid reimbursement program requirements to remain in
place.

School Nurses and Schools in general should be fully OPPOSED to these proposed changes.  For those of us working directly with these students, these changes would increase paperwork, take time away from care of children, and create another tedious step in the already burdensome process.  My primary job as a School Nurse should be to take care of students! 

I oppose the proposed changes to Medicaid reimbursement. RNs develop a plan in accordance with the physician order. This is within the scope of RN practice. Requiring additional approval and paperwork, in an already tedious process undermines the RN and takes time and resources from students.  Placing an additional and undue burden on school staff and health care providers, only results in lost revenue to schools and reduced services to students.

.

In agreement with previous posts, and as a school nurse, I emphatically oppose the proposed medicaid billing changes. These additional steps in obtaining approval and gathering additional paperwork would hinder valuable time in caring for students.

I oppose the changes.  The changes that are being proposed are another example of an overly bureaucratic process in our healthcare system.  Additional paperwork takes additional time from the nurse and the physician, which means we are spending less time with the students who need our direct and immediate attention.   The registered nurses role is to help the student remain in the classroom thereby improving their chances for academic success.   Complicating the billing process will add time and money to already congested health care system.  We need DMAS to collaborate with schools not work against us.  I strongly oppose the changes.  

As the Special Education Director of Fluvanna County Public Schools, in Palmyra, Virginia I oppose the proposed changes by the Department of Medical Assistance Services (DMAS) to the Virginia school-based Medicaid reimbursement program.  

Our nursing supervisor has expressed strong concerns about the proposed changes and is telling me that with the increased workload already, these changes can’t be done without additional staff.  These changes would create a significant amount of additional work and cost for the nursing staff in our school division.  The priority or our nursing staff will always be services to students.  The paperwork they already do is extensive, this will make it even more so, yet it doesn’t increase services to students.  There are concerns with obtaining the required physician’s signature for each Plan of Care and concerns that this will likely result in a decrease in reimbursement for these services. Our nursing supervisor is telling me that the increased paperwork load for nursing services could mean that the nurses won’t do this and therefore will force our school division to hire more staff or to discontinue billing for these services. 

A decrease in Medicaid reimbursement dollars and an additional cost to our and I am sure other school divisions participating in the Medicaid reimbursement program is of great concern.  As the number of students with disabilities continues to increase, so do 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.  

LEA Agency Provider Manual Public Comment:

*Detrimental to the staff all the time that would have to be spent tracking down signatures

*Is the Medical community aware this will be required; *Are there implications if Medical offices do not comply?

*Increase cost of billing- mail, time and practitioners reviewing and signing

*Loss of funds due to delay in signatures and inability to bill for services and transportation.

*We would lose 50% of our billing if not able to bill transportation because of no services provided for speech, OT, PT and nursing services.

*How does this affect our students being serviced?

Nurses Comment

With the nurses having to take time to track a physician for signatures I would imagine that would be very cumbersome for them.  As they are already busy with students as it is, without having to incorporate another step to the process.

Personal Care Comment:

*Clarify- Does the supervision requirement go away then (every 90 days?)

*Would we need Physician's signature if it’s only daily needs i.e. toileting, ambulation or personal hygiene?

* AGAIN – How does this affect our students being serviced?

Reimbursement helps our schools so much with helping with expenses for related services, transportation and specialized instruction.  This would really HURT us!!

As a Medicaid Coordinator my job is to do Outreach in the community as well as process billing for transportation and coordinate with our providers which include PT, OT, Nurses, Personal Care and Speech to make sure our related services and billing process goes smoothly on a day to day basis.  In my opinion having physicians and nurse practitioners come on board, will be a lot more work and time which should which should be used for our students.  

The proposed changes in the DMAS LEA provider manual have been discussed with our Special Education department and Nurse Coordinator.  We are opposed to these changes, as we believe that they will seriously affect our division’s ability to bill for nursing services, personal care services, and transportation services.  The proposed changes will increase the amount of paperwork that is required of our nursing staff.  Billable hours will be lost due to the lag time that will occur waiting for doctors to provide multiple signatures.  Doctors may have to increase staff in their offices to assist with the extra paperwork.  Doctors may even charge a fee for processing which the family would have to pay.  There are students who see multiple doctors or doctors from other states.  Nursing staff will have to track paperwork from several offices, which will result in longer lag times and unbillable hours.  Multiple Plans of Care (POC) would have to be written, sent, tracked, and processed. If there were even the smallest error in the paperwork, the process would start all over.  In addition, if there is a change in the POC (which there could be several times throughout the year), this process would have to start again.  This extra paperwork for nurses takes away from their main and most important duty – collaborating with families, creating health care plans, and addressing the health needs of all of our students.

If this process were cumbersome for the nursing staff, it would be the same for our personnel in the Special Education and Transportation departments.  A school division would have to hire additional staff just to track this process.  As a small, rural school division, that is not an option for us.  If the proposed changes were approved, it may mean that schools would not be able to participate in Medicaid billing and reimbursement.  These funds help offset the lack of other funding from federal, state, and local entities.  Moreover, that would take away needed services from our students. 

We strongly encourage you to reconsider the proposed changes.  The process is cumbersome as it stands.  These changes would make that even worse.  

Orange County Public Schools opposes the proposed changes by the Department of Medical Assistance Services (DMAS) to the Virginia school-based Medicaid reimbursement program.  Specifically, 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 reimbursements to off-set the increasing cost of specialized instruction and related services.

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

I oppose and am concerned of changes to the DMAS LEA Provider Manual, These new changes will not benefit the students we are to care and provide for. This process will delay needed care and could end up with unnecessary cutbacks or injury to student or staff. Safety and health should go hand and hand and one should not be jeopardized for the other.

As the Medicaid Coordinator in SCPS, I am opposed to the proposed changes that the Department of Assistance Services (DMAS) wants to make to the Virginia school-based Medicaid reimbursement program.  The proposed changes would require a physician's signature for each Plan of Care for nursing and personal care services.  Currently, only nursing services require a physician's signature, while ADL's require no signature from the physician.  This creates a tremendous amount of additional work for our nurses not to mention the staff at the doctor's office.  Many times, there is a wait time for theses signatures which would cost the school division a loss of revenue.  In addition, transportation reimbursements would be affected since billing for transportation depends on other billable services being delivered.

As the number of students with disabilities increase in our county, the cost of providing these services fails to keep pace.  The funding that is received from Medicaid reimbursement helps to offset that rising cost of specialized instruction and related services.

Please allow the current school-based Medicaid reimbursement program requirements to stay the same.

Mathews County Public Schools opposes the proposed changes by the Department of Medical Assistance Services (DMAS) to the Virginia school-based Medicaid reimbursement program. The proposed changes requiring a physicians signature for each Plan of Care for nursing and personal care services could force school divisions to discontinue billing for these services. These changes would create additional work and costs to local school divisions.  The required physician signatures may be difficult to obtain, and will likely result in a decrease of reimbursement for these services.  This proposal could also negatively impact billing for transportation services since billing for transportation depends on billing for other services.

Mathews County is a rural school division and many of our students with disabilities have to travel a great distance to see specialized physicians.  The requirement proposed will be a burden to many.  A decrease in Medicaid reimbursement will negatively impact the services our students receive. 

We urge you to reconsider the proposed changes and allow the current requirements to stay in place.

Arlington Public Schools opposes the proposed changes by the Department of Medical Assistance Services (DMAS) to the Virginia school-based Medicaid reimbursement program. Specifically, 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.

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

The proposed changes by DMAS to the Virginia school-based Medicaid reimbursement program will have a detrimental impact on Harrisonburg City Public Schools.  Having the Nursing Plan of Care signed by the physician will cause extra work and loss of revenue for school divisions and the State.  The signing of the Plan of Care by the physician unfortunately will not be a top priority for the physician and will result in services being given and not billed for in turn affecting cost report, interim billing, Billing Compliance Review, and Administrative Activity Claiming.  Who will be responsible for following up with physicians to get them to sign plans of care? Who will be responsible for paying for the doctor’s time to sign these plans of care?  How can we ensure each physician signs the plan of care and returns it to the school division?   Getting physician signatures is problematic and may result in the parent revoking permission for billing of Medicaid.  One student multiple doctors with multiple orders could result in excessive paperwork in tracking the time of administering medication/nursing services per each doctor. 

Potential financial obligations for the school division when doctor signs order for personal care and communicates with the parent and parent expects for the school to have it implemented in the IEP (one on one).  The concerns in regards to the nursing Plan of Care will have the same effect on Personal care.

A decrease in Medicaid reimbursement dollars and an additional cost to school divisions for participating in the Medicaid reimbursement program is of great concern.  The number of students with disabilities has increase significantly over the years as well as complexities of students’ needs.  As federal, state, and local education funding is not able to keep pace with the cost of providing special education resulting in school divisions to rely more on the Medicaid reimbursement to off-set the increasing costs.

The proposed changes to the manual do not provide clarification or guidance for psych, nursing, personal care, and transportation. Time and services used to track all of this paperwork will affect the monies that would be used to benefit the students could ultimately result in numerous school divisions discontinuing the billing of nursing, personal care, psych, and transportation.

The current school-based Medicaid reimbursement program requirements need to remain in place or another alternative other than what is being recommended needs to be considered.

Harrisonburg City Public Schools opposes the proposed changes by DMAS to the Virginia school-based Medicaid reimbursement program.  Having to have the Nursing Plan of Care signed by the physician will cause extra work and loss of revenue for school divisions and the State.  The signing of the Plan of Care by the Physician unfortunately will not be a top priority for the physician which will result in services being given and not billed for in turn affecting the cost report, interim billing, Billing Compliance Review, and Administrative Activity Claiming.  Doctors generally charge for filling out forms.   Who will be responsible for these charges?  This could result in the parent revoking permission for billing of Medicaid.  One student with multiple doctors' orders could result in excessive paperwork in tracking the time of administering nursing services for each doctor.

Potential financial obligations for the school division when the doctor signs order for personal care, communicates this to the parent, and parent expects the school to have it implemented in the IEP (one on one).  The concerns in regards to the nursing Plan of Care will have the same affect on Personal care as well.

A decrease in Medicaid reimbursement dollars and additional cost to school divisions for participating in the Medicaid reimbursement program is of great concern.  The number of students with disabilities has increased significantly over the years as well as complexities of students' needs.  As federal, state, and local education funding is not able to keep pace with the cost of providing special education resulting in school divisions to rely more on the Medicaid reimbursement to off-set the increasing costs.

The proposed changes to the manual do not provide clarification or guidance for psych, nursing, personal care, and transportation.

Time and services used to track all of this paperwork will affect the monies that would be used to benefit the students could ultimately result in school divisions discontinuing the billing of nursing, personal care, psych, and transportation.

The current school-based Medicaid reimbursement program requirements need to remain in place.

Arlington Public Schools opposes the proposed changes by the Department of Medical Assistance Services (DMAS) to the Virginia school-based Medicaid reimbursement program.  Specifically, 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. 

Having to have the Nursing Plan of Care signed by the physician will cause extra work and loss of revenue for school divisions and the State.  The signing of the Plan of Care by the physician unfortunately will not be a top priority for the physician will result in services being given and not billed for in turn affecting cost report, interim billing, Billing Compliance Review, and Administrative Activity Claiming.  Doctors generally charge for filling out forms.   Who will be responsible for these charges?  This could result in the parent revoking permission for billing of Medicaid.  One student multiple doctors with multiple orders could result in excessive paperwork in tracking the time of administering medication/nursing services per each doctor.  How do we know that the ordering physician is a registered ORP especially with the urgent care facilities?

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. 

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

The proposed changes will impede APS from seeking reimbursement for nursing, personal care and transportation.  The additional revenue would help APS offset the cost of providing the IEP services, which will in turn would provide better resources to make the student(s) successful.

As a special education administrator, I oppose the proposed changes by the Department of Medical Assistance Services (DMAS) to the Virginia school-based Medicaid reimbursement program.  Specifically, the proposed changes that would require a physician's signature for each Plan of Care for nursing and personal care services which 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 is increasing from year to year, so are the complexity of the 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 reconsider these proposed changes and allow the current school-based Medicaid reimbursement program requirements to remain in place.  

As a special education administrator, I oppose the proposed changes by the Department of Medical Assistance Services (DMAS) to the Virginia school-based Medicaid reimbursement program.  Specifically, the proposed changes that would require a physician's signature for each Plan of Care for nursing and personal care services which 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 is increasing from year to year, so are the complexity of the 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 reconsider these proposed changes and allow the current school-based Medicaid reimbursement program requirements to remain in place.  

September 18, 2019

Public Comment Opposing the proposed changes to the Virginia school-based Medicaid reimbursement program

As an employee of Virginia Beach City Public Schools, I oppose the proposed changes by the Department of Medical Assistance Services (DMAS) to the Virginia school-based Medicaid reimbursement program.  Specifically, 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.  This requirement could also result in costs to the school division as many physician’s offices now charge fees for paperwork completion. 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. 

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

 Sincerely,

Jill J. Robinson

Special Education and Medicaid Coordinator

Virginia Beach City Public Schools

September 18, 2019

Public Comment Opposing the proposed changes to the Virginia school-based Medicaid reimbursement program

As an employee of Virginia Beach City Public Schools, I oppose the proposed changes by the Department of Medical Assistance Services (DMAS) to the Virginia school-based Medicaid reimbursement program.  Specifically, 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.  This requirement could also result in costs to the school division as many physician’s offices now charge fees for paperwork completion. 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.  

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

Sincerely, 

Mandi Cumpston 

Special Education Coordinator

Virginia Beach City Public Schools

September 19,2019

Public Comment Opposing the proposed changes to the Virginia school-based Medicaid reimbursement program

As an employee of Virginia Beach Public Schools, I oppose the proposed changes by the Department of Medical Assistance Services (DMAS) to the Virginia school-based Medicaid reimbursement program.  Specifically, 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.  This requirement could also result in costs to the school division as many physician's offices now charge fees for paperwork completion.  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.

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

Sincerely,

Katrina Ward, OTR/L

Occupational Therapist and Medicaid Compliance

Virginia Beach Public Schools.

As Medicaid Coordinator for Fredericksburg City Public Schools, I appose the prosed changes by DMAS to the Virginia school-based Medicaid reimbursement program.  The proposed changes would require a physician signature for each Plan of Care for nursing and personal care services.  This change could force our division to stop billing for these services. This requirement would create and additional amount of work and cost for the school division. The signature for each Plan of Care may be difficult to obtain which would decrease reimbursement for these services.  The division mostly face additional costs as most Physicians now charge fees for paperwork.  These new changes would also effect school division transportation reimbursements as billing for transportation requires other billable services.

These changes would decrease Medicaid reimbursement amount and additional costs if a great concern.  The number of students with disabilities had increased greatly over the years as well as the students needs.  Federal, state and local funding are not able to keep with the funding needs which results in school division relying more on Medicaid reimbursements.

The proposed changed do not provide clarification or guidance for psych, nursing, personal care, and transportation.

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

Hopewell City Public Schools opposes the proposed changes by the Department of Medical Assistance Services (DMAS) to the Virginia school-based Medicaid reimbursement program.  Specifically, 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 our division.  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 will likely negatively impact our division's transportation reimbursement, since billing for transportation depends on other billable services. 

A decrease in Medicaid reimbursement dollars and an additional cost to our division 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. 

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

VCASE opposes the proposed changes by the Department of Medical
Assistance Services (DMAS) to the Virginia school-based Medicaid
reimbursement program. Specifically, 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.
We urge you to reconsider these proposed changes and allow the current
school-based Medicaid reimbursement program requirements to remain in
place.

The Virginia Council of Administrators of Special Education opposes the current proposed  changes by the Department of Medical Assistance (DMAS) to the school-based Medicaid reimbursement program.  Specifically, the proposed change to 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 work and cost for school divisions.  The requirement of the physician's signature will be difficult to obtain and will likely result in a decrease in reimbursement to school divisions.  In addition, complications of billing for nursing and personal care services could impact divisions' reimbursement for transportation services since billing for transportation depends upon other billable services.

A decrease in Medicaid reimbursement dollars and an increase in costs to schools divisions participating in the program is of great concern.  As the number of students with disabilities increased (24% in Virginia over the last four years) so did the complexities of student needs.  Consequently, federal, state, and local education funding fails to keep pace with the cost of educating students with disabilities causing school districts to rely more and more on Medicaid reimbursement to off-set the increasing costs of specialized instruction and related services.

We urge you to reconsider the proposed changes and allow the current school-based Medicaid reimbursement requirements to remain intact.  

Wise County Schools is opposed to the proposed changes to the LEA manual!

All Virginia physicians must be made aware of what their responsibilities are now verses what the proposed changes will require them to do. In our opinion, they will also be in disagreement with the proposed changes. It is an extremely difficult and time-consuming task simply getting the doctor's order returned with the required information. We have already experienced physicians resit in providing their NPI numbers. 

The proposed changes will significantly affect the school division's nursing, personal care, and transportation reimbursement by adding additional time and cost. It will be even more difficult to get practitioners to comply, and will untimely impact services to students.  Funding that school divisions receive for education funds fails to cover the cost of the consistently growing needs of our students with disabilities.

Wise County is a rural community with few resources and Medicaid reimbursement allows us to provide services that may otherwise be inaccessible for our students. The Medicaid reimbursement we receive helps our school system with our service expenses and gives us the ability to provide those much needed services. 

We urge you to reconsider the proposed changes!

As the School Nurse Coordinator for our division and on behalf of our nurses,   I strongly oppose the the proposed changes in the school-based  Medicaid reimbursement program.  I have participated in Medicaid Billing with students for the past eight  years and  am speaking to the practical application of these proposals. I am addressing them based on my opinion that the RN is highly qualified to develop  strong, evidence-based Plans of Care for  students  without  the need for review and signature of the physician.  She sees the students daily;  she knows the goals that need to be established for the student to be compliant with physician's orders.  

The current process is cumbersome and requires strict attention to detail with no room for error.   If the school nurse is billing for multiple students, this is not easily accomplished during a school day without  compromising  student health care needs.  The nurse often completes this work beyond school hours.   If these new proposals are approved and implemented,  they will result in a further increase in time to create, track, process and complete required paperwork, utilizing the same narrow criteria, for each student.  The nurse may end up being forced to choose between taking time away from student care,  using even more of her personal time after school, or refusing to participate, none of which are good options for the student, the nurse, or the school division. 

The requirement of physician review and signature on a Plan of Care will result in a loss of  billable services revenue as the nurse has no control over the willingness  or the efforts of the physician/office staff to comply with requests in a timely manner.

If multiple physicians are ordering services for one student, the nurse will have to track this process with each physician  which is overwhelming in and of itself.   Added to this is the loss of  exponentially increased billing services revenue because of wait time.  If the nurse has multiple students with multiple physicians,  the process can quickly become unsustainable.  Her capability to provide high quality student health care utilizing best practices will be significantly impacted.  Something will have to give and it should never, ever be student care.  To place her in this position is  unfair and unreasonable, and undermines her work as a professional school nurse.

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

As an employee of Virginia Beach City Public Schools, I oppose the proposed changes by the Department of Medical Assistance Services (DMAS) to the Virginia school-based Medicaid reimbursement program.  Specifically, 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.  This requirement could also result in costs to the school division as many physician's offices now charge fees for paperwork completion.  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.  

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

Sincerely, 

Christen Cohoon 

Special Education and Medicaid Coordinator

Virginia Beach City Public Schools

1. Chesterfield County Public Schools is opposed to the proposed changes by the Department of Medical Assistance (DMAS) to the Local Education Agency Provider Manual. After reviewing the suggestive changes by DMAS, it seems that each area a school division can seek reimbursement for is affected. The most significant of these proposed changes are to the nursing and personal care services. By getting a physician to sign a Plan of Care for each student’s treatment (which could be 1 to 5 or more for each student) would be adding extra burden on the school division.  Not to mention the physicians billing the school district for signatures. The wait time to get the signed Plan of Care back from the physician would be lost revenue.(Can’t bill for services until we get the signed POC back.) The nurse’s and the personal care assistants will be spending more time on paperwork than checking on their students health needs. Please reconsider these proposed changes and allow the current Local Education Agency Provider Manual stay in place.

2. Chesterfield County Public Schools (CCPS) is opposed to the proposed changes to the Local Education Agency Provider Manual by the Department of Medical Assistance (DMAS). A school district the size of CCPS with over 7,000 Special Education students could be impossible to manage with the current staff we have available. Under the proposed changes to Nursing and Personal Care Services that would put CCPS over 15,000 Plans of Care to keep track of just for nursing and personal care. We would have to add on staff just to help with those two areas, with money we don’t have. Please reconsider these proposed changes and allow the current Local Education Agency Provider Manual stay in place.

Arlington Public Schools opposes the proposed changes by the Department of Medical Assistance Services (DMAS) to the Virginia school-based Medicaid reimbursement program.  Specifically, 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. 

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

DMAS’ proposed NEW REQUIREMENTS to the Local Education Agency Medicaid Manual will adversely affect the success of the Virginia School-Based Medicaid Reimbursement Program. If implemented, the major changes in requirements for Nursing Services and Personal Care Services would significantly increase workload on Nursing staff and Medicaid billing staff at the schools. When schools are forced to discontinue billing of these services due to workload/additional costs, or cannot comply with requirements due to external factors, the result will be a significant decline in reimbursements.
To explain, the requirements of physician signature on every Plan of Care, on every Plan of Care Addendum, separate student logs for each physician, documenting per doctor in fifteen-minute units, and submitting billing claims per student per doctor will result in the following issues:
When Physicians do not sign or do not return Plans of Care, schools cannot bill for those services delivered as outlined on the unsigned Plans of Care. When Physicians delay in returning the signed Plans of Care documents, the result is not billing for delivered services until signed documents are returned to schools. Multiple Plan of Care Addendums not signed or returned timely have the same result. All of the missed billing negatively affects the interim billing, cost report, and the billing compliance review.
How far in advance/how much time do you give a physician to sign Plans of Care? POCs are time-sensitive documents. How much time/effort do you spend trying to get them returned? Do we risk the security/confidentiality of this information every time these documents are exchanged from school to Physician and returned. Physicians could require parents to bring in the Plans of Care for signature. Parents may be reluctant and decide to revoke their parental consent for billing Medicaid resulting in no services billed for that student. Physicians may charge for their signatures. Can schools claim the expense on their cost report for reimbursement? Physicians may increase the signature rate if they have a large volume of POCs to sign. Students with disabilities tend to have numerous physicians.
Nurses will spend more time on administrative tasks including separate POCs for each Physician, separate student logs for each Physician, and totaling minutes by each Physician resulting in paying Nurses to work more hours. Medicaid billing staff will spend more time entering the claim data in the portal by student, by Physician, resulting in not enough time to perform these tasks, and Finance/Budget staff asking, is the reimbursement worth the increase in time/costs to process claims?
These proposed New Requirements will result in taking funds away from the REAL NEED, which is providing services, for students with disabilities. The cost of Special Education continues to increase, please reconsider and do not make these changes to the LEA Manual. Instead, find a more feasible solution to satisfying the NPI/ORP requirement for Nursing Services & Personal Care Services.

As a local special education director, I am very concerned about the proposed changes to the Virginia school-based Medicaid billing program.  Specifically, the requirement for 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, this change could create additional paperwork and cost for local school divisions.  A physician's signature for each Plan of Care could be significantly difficult to obtain and will likely cause a decrease in reimbursement for these services.  In addition, complications with billing for nursing and personal care services could jeopardize reimbursement for transportation services since reimbursement for transportation is dependent on other billable services.  

The potential of a decrease in Medicaid reimbursement dollars is of great concern to me in my division.  As the number of students with disabilities increases and the complexities of meeting these disability-related needs increase as well, federal, state, and local funding has failed to keep pace with the increased costs of educating students with disabilities.   My division relies more and more on Medicaid reimbursement funds to supplement the cost of specialized instruction and related services.  

I urge you to reject the proposed changes and keep the current Medicaid procedures in place.  

Thank you.

We, the members of the Virginia Association for Behavior Analysis (VABA) Public Policy Committee propose the following additions to the manual:

In Chapter II of the Local Education Agency Provider Manual, page 8 (also Chapter IV, page 1,2; Chapter V, page 10) include “Applied Behavior Analysis” as a covered service.  Behavior Analysts are often key team members in public schools and can help with behavior assessments and intervention plans, skill-building, and both individual student and group-focused work.  There is extensive research on behavior analysis in schools.  For a fact sheet, go to https://www.bacb.com/wp-content/uploads/Behavior-Analysis-in-Education-Fact-Sheet_190520.pdf.  Note that the legislature voted in 2019 to include Licensed Behavior Analysts in the budget language using at-risk funds.

In Chapter II, on page 9, Licensed Behavior Analysts and Licensed Assistant Behavior Analysts should be included in the list of possible ORP providers.

In Chapter II, on page 10, Licensed Behavior Analysts and Licensed Assistant Behavior Analysts should be included as supervisors for “Assistance to increase adaptive behavioral functioning”

In Chapter II, on pages 10 -12, Applied Behavior Analysis (ABA) as provided or supervised by a Licensed Behavior Analyst (LBA) or Licensed Assistant Behavior Analyst (LABA) should be added.

In Chapter IV, on pages 6-11, Applied Behavior Analysis should be included as a service that is added into the IEP based on a functional behavior assessment and a written behavior plan. 

In Chapter IV, on page 13, Licensed Behavior Analysts should be added to those who can develop a written behavior modification plan (in addition to licensed psychological provider).

In Chapter V, on pages 23-31, the following codes should be added:

• 97151 – Behavior identification assessment
• 97153 – Adaptive behavior treatment by protocol
• 97155 – Adaptive behavior treatment with protocol modification (supervision)

In Chapter VI, ABA services should be included in the service-specific documentation requirements starting on page 4.

Even though it is permissible in the code of Virginia for school employees to provide services that look like the practice of behavior analysis within the scope of their duties, it is important to include Licensed Behavior Analysts in the list of DMAS approved providers for students.  LBAs have had the extensive training necessary to perform functional assessments and analysis and to write evidence-based behavior plans.

DMAS’ proposed NEW REQUIREMENTS to the Local Education Agency Medicaid Manual will adversely affect the success of the Virginia School-Based Medicaid Reimbursement Program.  If implemented, the major changes in requirements for Nursing Services and Personal Care Services would significantly increase workload on Nursing staff and Medicaid billing staff at the schools.  When schools are forced to discontinue billing of these services due to workload/additional costs, or cannot comply with requirements due to external factors, the result will be a significant decline in reimbursements. 

To explain, the requirements of physician signature on every Plan of Care, on every Plan of Care Addendum, separate student logs for each physician, documenting per doctor in fifteen-minute units, and submitting billing claims per student per doctor will result in the following issues:

When Physicians do not sign or do not return Plans of Care, schools cannot bill for those services delivered as outlined on the unsigned Plans of Care.  When Physicians delay in returning the signed Plans of Care documents, the result is not billing for delivered services until signed documents are returned to schools.  Multiple Plan of Care Addendums not signed or returned timely have the same result.  All of the missed billing negatively affects the interim billing, cost report, and the billing compliance review.

How far in advance/how much time do you give a physician to sign Plans of Care?  POCs are time-sensitive documents.  How much time/effort do you spend trying to get them returned?  Do we risk the security/confidentiality of this information every time these documents are exchanged from school to Physician and returned.  Physicians could require parents to bring in the Plans of Care for signature.  Parents may be reluctant and decide to revoke their parental consent for billing Medicaid resulting in no services billed for that student.  Physicians may charge for their signatures.  Can schools claim the expense on their cost report for reimbursement?  Physicians may increase the signature rate if they have a large volume of POCs to sign.  Students with disabilities tend to have numerous physicians.

Nurses will spend more time on administrative tasks including separate POCs for each Physician, separate student logs for each Physician, and totaling minutes by each Physician resulting in paying Nurses to work more hours.   Medicaid billing staff will spend more time entering the claim data in the portal by student, by Physician, resulting in not enough time to perform these tasks, and Finance/Budget staff asking, is the reimbursement worth the increase in time/costs to process claims? 

These proposed New Requirements will result in taking funds away from the REAL NEED, which is providing services, for students with disabilities.  The cost of Special Education continues to increase, please reconsider and do not make these changes to the LEA Manual.  Instead, find a more feasible solution to satisfying the NPI/ORP requirement for Nursing Services & Personal Care Services. 

Augusta County Public Schools opposes the proposed changes by the Department of Medical Assistance Services (DMAS) to the Virginia school-based Medicaid reimbursement program.  Specifically, 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.  

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

PCPS opposes the proposed changes by the Department of Medical Assistance Services (DMAS) to the Virginia school-based Medicaid reimbursement program.  Specifically, 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. 

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

The Virginia School for the Deaf and the Blind strongly opposes the proposed changes to Medicaid billing.  We are in an unique setting with students from all over the state of Virginia.  Many of our students see multiple specialists, so seeking out his/her prescribing provider can be hard enough....even more so since we are hundreds of miles apart.  Then to require that the physician write a prescription and additionally sign the plan of care seems redundant.  All the while, this process undermines the RN's capabilities to take the physician order and create the plan within their scope of practice.  Also, with these new proposed changes, if the medication changes, another order AND plan of care is needed....why is the order not enough?  Why are these changes requiring this additional step?  This increases the workload to not only the physicians, but to the nurses and medicaid billing staff.  When can we take care of the children in the schools if we are constantly calling, faxing, scanning, emailing to get these new requirements done? 

These proposed changes would significantly impact our Medicaid reimbursement. We heavily depend of physicians to sign and return medication orders.  Physicians are going to get fed up with the constant paperwork that takes him or her away from his or her other patients just to meet a Medicaid reimbursement procedure...so the signatures will stop and the reimbursement process with come to an end!  Or the physicians will place a fee to have these forms completed and signed?  Who takes on the responsibility for that cost?  If the school does, we will start losing money!  If the parent becomes responsible for the cost, they will decline any billing.  My bigger fear is that if we keep "hounding" the physicians for all of these redundant signatures, when will they stop signing any or all of the required school forms??  What happens to the children when they nurses can't obtain written medication orders because the physicians are fed up with the additional paperwork!  Think about all of this for long term!  Is this process really sustainable??  No!

We need to look at how this negatively impacts the children in our schools!  Physicians and nurses want to take care of children and we can't do our jobs effectively if we spend all of our time focusing on the paperwork!  I guess the real question is, who is really benefitting from these proposed changes?

Harrisonburg City Public Schools opposes the proposed changes by the Department of Medical Assistance Services (DMAS) to the Virginia school-based Medicaid reimbursement program.  Specifically, 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.

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