The Virginia Council of Administrators of Special Education opposes the current proposed  changes by the Department of Medical Assistance (DMAS) to the school-based Medicaid reimbursement program.  Specifically, the proposed change to require a physician's signature for each Plan of Care for nursing and personal care services could force school divisions to discontinue billing for these services. At best, these changes would create a significant amount of work and cost for school divisions.  The requirement of the physician's signature will be difficult to obtain and will likely result in a decrease in reimbursement to school divisions.  In addition, complications of billing for nursing and personal care services could impact divisions' reimbursement for transportation services since billing for transportation depends upon other billable services.

A decrease in Medicaid reimbursement dollars and an increase in costs to schools divisions participating in the program is of great concern.  As the number of students with disabilities increased (24% in Virginia over the last four years) so did the complexities of student needs.  Consequently, federal, state, and local education funding fails to keep pace with the cost of educating students with disabilities causing school districts to rely more and more on Medicaid reimbursement to off-set the increasing costs of specialized instruction and related services.

We urge you to reconsider the proposed changes and allow the current school-based Medicaid reimbursement requirements to remain intact.