The proposed changes by DMAS to the Virginia school-based Medicaid reimbursement program will have a detrimental impact on Harrisonburg City Public Schools.  Having the Nursing Plan of Care signed by the physician will cause extra work and loss of revenue for school divisions and the State.  The signing of the Plan of Care by the physician unfortunately will not be a top priority for the physician and will result in services being given and not billed for in turn affecting cost report, interim billing, Billing Compliance Review, and Administrative Activity Claiming.  Who will be responsible for following up with physicians to get them to sign plans of care? Who will be responsible for paying for the doctor’s time to sign these plans of care?  How can we ensure each physician signs the plan of care and returns it to the school division?   Getting physician signatures is problematic and may result in the parent revoking permission for billing of Medicaid.  One student multiple doctors with multiple orders could result in excessive paperwork in tracking the time of administering medication/nursing services per each doctor. 

Potential financial obligations for the school division when doctor signs order for personal care and communicates with the parent and parent expects for the school to have it implemented in the IEP (one on one).  The concerns in regards to the nursing Plan of Care will have the same effect on Personal care.

A decrease in Medicaid reimbursement dollars and an additional cost to school divisions for participating in the Medicaid reimbursement program is of great concern.  The number of students with disabilities has increase significantly over the years as well as complexities of students’ needs.  As federal, state, and local education funding is not able to keep pace with the cost of providing special education resulting in school divisions to rely more on the Medicaid reimbursement to off-set the increasing costs.

The proposed changes to the manual do not provide clarification or guidance for psych, nursing, personal care, and transportation. Time and services used to track all of this paperwork will affect the monies that would be used to benefit the students could ultimately result in numerous school divisions discontinuing the billing of nursing, personal care, psych, and transportation.

The current school-based Medicaid reimbursement program requirements need to remain in place or another alternative other than what is being recommended needs to be considered.