As the Medicaid Support Specialist, I echo many of the previous comments regarding the proposed updates to the LEA manuals. These updates will result in a significant increased workload for all staff involved in providing these services. Administration will now need to maintain separate POCs for students who have multiple referring physicians. They will need to monitor and track which POCs have signatures. Nurses and personal care aides will need to document services per referring physicians, which will result in more time away from students, impacting their overall care throughout the school day. Additionally, the DMAS portal is not currently set up to reimburse for multiple claims for a student for nursing/personal care services in a single month. With these new requirements, divisions will possibly need to submit multiple nursing/personal care claims for a student per month (depending on how many referring physicians the student has). This will result in increased costs for the division along with reduced reimbursement. Claims, when split across multiple physicians, may no longer make up one unit to seek reimbursement for. These new requirements will have significant impact on cost reporting and BCR reports. If services are delivered, but cannot be billed because the division is waiting on a physician signature, the division will be penalized. The potential reduction in reimbursement, both in direct service claims and administrative claims will be significant - especially for smaller division that rely on Medicaid reimbursement to fund the services to their students. This reduction in reimbursement funds will have an impact on how effectively students are served within that division. This will also have an impact on transportation services. Again, if waiting on a physician signature, transportation services cannot be submitted for reimbursement. Why continue to require the statement in the IEP if services need to be ordered by a physician? These new requirements and the substantial increase in workload that they are going to require may force some divisions to no longer seek reimbursement for nursing/personal care services.
In addition to the general comments made on the updates proposed on nursing/personal care services, there are many factors of this manual that are not clear to providers or to school administration.
Chapter IV
On page 5 - clarification - did DMAS remove the limitation of 6 students per group? What if there are no individual practice guidelines for an appropriate group size limit? This could provide ethical dilemmas for therapists who may be asked to serve large groups of students because there is no longer a limit. This will drastically reduce the quality of services that are being provided.
On page 6 - why remove the (obvious) statement that services are considered for termination (requiring a discharge summary) when a student is no longer found eligible for special education services/no longer identified as having a disability?
On page 6 - clarification on short term goals for PT services - why make this statement for only PT? Will short-term goals now be required for PT on a POC? This will increase the workload for staff members, taking away from their time to serve students in the school setting.
On pages 6-10 - why not make the wording of the therapy service requirements? PT services are listed differently than OT, Speech and Audiology
On page 9 - why remove the ability to submit claims for the personal care aide that is required to attend the therapy session with the student receive the teletherapy service? This could result in divisions not able to submit reimbursement for teletherapy services rendered to students when no SLP is available for direct hire/contracting.
Chapter V
The procedure codes for OT and PT assessments are incorrect. They should be:
OT - 97167
PT - 97163
Procedure codes for psychological assessments are not clear
Chapter VI - there are many requirements listed in this chapter that are not listed in any other chapter, making the requirements unclear to both providers and administrators.
On page 4 - why combine EPSDT Screenings and Medical Evaluations? EPSDT screenings are not related to special education and Medical Evaluations are only reimbursable when required by a special education team? These two processes should not be merged.
On page 5 - for POC documentation, in a previous chapter, the statement requiring interventions, treatments and modalities was removed, but is included again here?
On page 5 - for PT, in a previous chapter, short terms goals were also a requirement
On page 6 - the route of administration in nursing documentation is a new addition. This is not included in previous requirements in other chapters
On page 8 - how is a school psychologist expected to document their clinical decision making?
I respectfully ask that DMAS thoughtfully consider all of the public comments that have been made before implementing changes that will have a significant impact on school divisions (and the service delivery to students) across the state.