Thank you for the opportunity to comment on the new requirements being proposed in the revised LEA provider manual. As the Director of Special Education Services for a smaller school division, I vehemently oppose the proposed new requirements. The loss of any Medicaid funds would negatively impact our school division’s bottom line, which in turn would negatively impact the education of our students.
The new requirements place significant hurdles to the management of required documentation into a and will place unreasonable time demands upon our school nurses, which ultimately takes them away from serving students. Currently, when a School Nurse receives a doctor’s order, they develop a Plan of Care (POC) and send a copy of the POC (including any amendments) to the student’s physician. The nurse can begin delivering services based on the doctor’s orders and the services can be billed to Medicaid. The new requirement will still require the School Nurse to write a POC and send it Realistically, there is no incentive for a physician to send the signed documentation back—and I am certain they will not. They pay their staff to manage the necessary day to day operations of their office and I do not anticipate physician’s placing a priority on signing and having their staff take the time to prepare and return POC’s so a school division can bill Medicaid.
Another time consuming matter for the school division is the tracking and filing of signed POCs. A tracking system would have to be developed to know which POC’s have been mailed, the date they were mailed, and if they were signed and returned. School divisions would have to create management criteria such as how many attempts would be made to get a signed POC, how many days must a school division wait before sending a second request, etc. What a waste of precious time that could be devoted to assisting students.
From a financial standpoint, this requirement creates a cost factor for schools. To feasibly expect a return of the POC, the school division would likely need to send a stamped envelope with their return address with the POC. This would take time and resources (envelopes and postage) from the school division since someone would have to prepare the return envelope and place postage on it. While, it may increase the chances of the signed POC being returned, (since the doctor’s staff would not be taking the time to prepare an envelope and the physician is not paying for postage) if the POC is not returned, the school division has lost time and resources. This may not initially seem to make an impact on costs, but when one considers that the new requirements require a signed POC for each amendment, each ordering physician, and the fact that POCs may have to be mailed multiple times, the preparation time and postage cost incurred to a school division could be significant.
If the new requirements are implemented, Medicaid should allow school divisions to bill for:
By allowing administrative billing for the above mentioned items, a school division could receive some reimbursement for time and labor even if a POC is not signed and returned.
The proposed requirements would punish school divisions by not allowing them to bill for nursing services unless a signed POC was in hand. Not only would potential reimbursement be lost for nursing services, but transportation reimbursement would also be reduced—another negative impact for school divisions. The new requirements are making reimbursements for nursing services dependent on a physician’s signature, for which they have no motivation to complete. Please re-consider these proposed changes so that school divisions are not negatively impacted.