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.