Effective March 25, 2011, Federal regulation 42 CFR 455.410(b) required that:
“The State Medicaid agency must require all ordering or referring physicians or other professionals providing services under the State plan or under a waiver of the plan to be enrolled as participating providers.”
What this means is that all Occupational Therapists, Physical Therapists, Speech Therapists, and any other direct service MSP providers are required to obtain an Ohio Medicaid Provider Number. Knowing that this enrollment would not be very popular with your therapists, HBS and HPC teamed up in 2014 and hired the firm of Squire-Patton-Boggs for a legal opinion and to lobby the Ohio Department of Medicaid (ODM) to fight this requirement. I have to commend ODM for their efforts, because as you can see from the attached letter from CMS, ODM did “go to bat” for Ohio school districts. Although we were able to delay this requirement for the past several years, we ultimately did not get the decision from CMS that we were hoping for. Beginning August 1, 2016, MSP direct service therapists will be required to obtain an Ohio Medicaid Provider Number. This requirement should not affect Nurses, because they provide services based on a physician prescription, or Psychologists, because they do not typically provide “Direct Services”.
CMS has given the Ohio Department of Medicaid two options:
1. Require school districts to obtain a physician prescription for all services.
2. Require therapists to obtain a State Medicaid Provider Number.
Obtaining physician prescriptions would require ongoing data collection from multiple sources, whereas the provider enrollment would be a one-time process. The online Medicaid enrollment process is a condensed version of the Medicaid application that school districts had to go through to get their Medicaid Provider Number. There will not be a state application fee for therapist enrollment.
On January 27, 2016, the Ohio Department of Education will be hosting a webcast regarding this change. We will wait until after this webcast to distribute information to your therapists, and we will have various tools in place that will make this a simple process for your therapists. We will have step by step instructions posted in our documentation system, on our website, and we will have YouTube training videos and an enrollment helpline.
The first step for your therapists is to apply for a National Provider Identification (NPI) number. This is a Federal Provider Number that most therapists have already obtained, which will be required for the State enrollment. Your quarterly “Documentation Received by Therapist” report indicates which therapists still have not obtained an NPI number.
I will caution you up front that therapists were not very happy to have to obtain the NPI number, and they will not be at all pleased with having to get the State Provider Number. This requirement is an Affordable Care Act (ACA) mandate and is designed to cut down on fraud and identity theft. This will provide therapists with another level of protection against someone using their license and identity to commit Medicaid fraud.
We will do whatever it takes to get all therapists enrolled by the August 1, 2016 deadline, and we will continue to put systems in place to make the Medicaid documentation process as efficient as possible. I will cover this issue in more detail after the January 27 webcast. If you have any questions, please contact our office.
10/23/2015 letter from CMS (Ohio-MSP-Letter-20151023)
01/21/2016 letter from ODE (Zake Email)