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