As the Director of Special Education for Hampton City Schools, Hampton, VA, this serves as written opposition of the proposed changes to the Virginia school-based Medicaid reimbursement program. The proposed changes will require school divisions to take additional steps when documenting billable services- steps that would require dependency on Physicians. Specifically, one of the proposed changes would require a physician's signature for each Plan of Care for Nursing and Personal Care Services. This would leave divisions dependent on receipt of signed document(s) in order to bill for services. Physician's signature may be difficult to obtain which would result in a decrease in reimbursement for these services. These changes would also create complications for billing for Nursing and Personal Care Services which would adversely impact our divisions' transportation reimbursement since billing for transportation depends on other billable services.

The number of students with disabilities in Virginia has increased over the past four years (increased by 24%) as has the complexity of students needs. Consequently, federal, state, and local education funding fails to keep up with the cost for providing special education services to our students. As a school division, the Medicaid reimbursement helps 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. Thank you for taking the time to read this public comment and for your consideration.