Montgomery County Public Schools opposes the proposed changes to the LEA policy manual.  The changes obviously will require increased workload on the current Medicaid billing staff, nursing staff and physicians, however, of major concern is how decreased funding will impact students with disabilities,, as well as the general student population.  Yearly funding to public schools becomes more limited at the federal, state and local levels, however, student "need" increases within the public schools.  Medicaid reimbursement is intended to be used to offset expenses incurred by public schools due to increased need in services and materials for students with disabilities.  The reduction in revenue received from Medicaid due to decreased billing will result in limitations placed on schools to provide students with resources needed whether that is, for example, purchased materials or increased purchased professional services to work more closely with students.  

Many of our students see multiple physicians.  Physician offices will not be able to handle the increased paperwork and more than likely will NOT return the school documentation.  Physicians may also implement a fee for completing paperwork.  Physicians are already writing the order(s) for medication administration and nursing procedures before the student is administered medication or services at school.  It would be redundant to have the physician turn around and sign the school plan of care when it is written as ordered from the physician from the beginning. 

The decision to implement targeted assistance (one-on-one) to a student with disabilities is an educational (LEA) decision and not a medical decision.  Physicians may provide input, however, they do not make the decisions of whether their patient (our student) should receive one-on-one targeted assistance during the school day.  That decision is an IEP team decision.  Therefore, physicians should not be required to write an order for a student to receive assistance at school and/or be required to sign off on Personal Care Assistant paperwork when he/she is not within the line of sight of the student and PCA to see the services being carried out.  

It appears there are multiple unknowns as to how the proposed changes to services will be implemented, the financial impact on school divisions, the requests of private sector physicians to monitor school services, but most importantly how the proposed changes will affect services provided to all students within the public schools.  MCPS urges you to reconsider implementing the changes to the LEA manual and the impacts the changes will have on public education.