Chapter VI of the updated LEA manual now states that “All documentation requiring a provider signature must use a signature format including the first initial, last name, and title of the provider and dated no later than 14 calendar days from the service delivery.” As a school based administrator, I have concerns about how this will impact our providers. We use a vendor for Medicaid reimbursement and our providers are required to enter in their documentation monthly. If a time frame is required, could it be placed at 45 days for signatures from the service delivery? If the 14 day requirement is kept, our providers will have to maintain two sets of documentation to “prove” that they have documented the service within the 14 days and the electronic version of the documentation, which could prove problematic during IDEA due process situations. All Medicaid documentation is, at its core, data entry from the clinical documentation that a therapist maintains during therapy sessions. Divisions that use a vendor will now be held to a stricter standard as there is back-end documentation on when a service is entered and signed.

Additionally, there are 1-year timely filing requirements. If a school division finds out in March that a student is now eligible for reimbursement beginning in January (and they are only requiring their providers to provide documentation on Medicaid eligible students), they will miss out on any potential back billing because of this 14 day signature requirement.

Additionally, LEAs operate differently than medical and private therapy settings. Missed days due to holidays, snow days, extended leaves due to natural disasters, etc. could impact a providers’ ability to sign documentation within the 14 day guidelines.