I stand with my state association, The Speech-Language Hearing Association of Virginia, in opposition to the proposed changes by the Department of Medical Assistance Services to the Virginia School-based Medicaid reimbursement program.

I agree with the concern that this will make billing difficult and ultimately costly to the public schools of Virginia which are already experiencing financial impacts from the increased number of children requiring services.  

I would like to add that in my opinion this requirement asks the physicians to act outside of their scope of practice.  Not all of the children eligible for medicaid, whom I will evaluate, have a medical need for the speech-language evaluation; instead, they have an educational need for the speech-language evaluation.  It is my job and in my scope of practice to determine if the child requires my specialized instruction in order to fully access the curriculum in accordance with FAPE.  Physicians do not have this knowledge; therefore, they should not have the obligation to sign off on an evaluation request for a medicaid eligible student.  Additionally, my POC information comes from the IEP and the goals and services developed by the IEP team for each child.  IDEA regulations do not mandate that physicians be a part of this team; therefore, they do not have the right to decide if the POC that comes from the IEP is acceptable.  I foresee this as a potential legal nightmare that will be costly to both the schools and the medical community and ultimately the Commonwealth.