11/16/15: Concerns with Misinformation

Mark Smith, Ohio Department of Education
Yolanda Talley, Ohio Department of Medicaid

I can no longer idly sit by and let a small group of individuals bring down the Ohio Medicaid School Program (MSP) that so many have worked so hard to build. Our MSP Stakeholder group continues to work to build integrity and accountability to our program, while other organizations operate under misinformation and misrepresentations. You both know that I have always worked very well with the other billing vendors in the Ohio Medicaid School Program, but there is one billing vendor in particular that is using false information to lure school districts into switching to their firm.

We have been aware for some time now that the billing vendor MSB was doing revenue projections for services that are not currently part of MSP, mainly Delegated Nursing and Personal Care Services. We are expecting ODE to release correspondence in the coming days that sets the record straight regarding “Current Reimbursable MSP Services”. We now learn that this vendor is doing “Revenue Comparisons”, but are not using accurate information of what districts are currently receiving in total MSP reimbursement, or what a district should be receiving.

The attached spreadsheet relates to school districts in Summit County. The only school district that HBS currently represents in Summit County is Akron Public Schools and Green Local Schools, so none of these districts are current clients of HBS. I have nothing to gain from this email other than the integrity of the program that I have spent my 28 year career building and supporting. The assumptions one would make based on this spreadsheet are very misleading. This spreadsheet attempts to show:

MSP dollars the Summit districts received in 2010/11 MSP Reimbursement?
MSP dollars MSB could have gotten them for 2010/11 MSP Reimbursement?
MSP dollars each district could generate if House Bill 89 passes?

I would like to first point out that the 2010/11 Medicaid School Program year was only a 9 month period, as the MSP program converted from a Federal Fiscal Year to a School Fiscal Year (10/01/10 – 06/30/11). Any revenue analysis would need to factor the 9 month year into the comparisons, which were not done on this spreadsheet.

Notice that MSB clients Copley-Fairlawn, Norton, and Stow-Monroe are magically getting exactly what they should be ($39,401, $50,719, and $28,603) according to this spreadsheet.

If you just look at the first district listed, which is Barberton City Schools, you can clearly see how deceiving this spreadsheet really is. The “Dollars Returned in 2011” amount of $130,238 is totally incorrect. Barberton actually received $268,027 for 10/11 ($137,788 Interim + $130,239 in Final Settlement reimbursement), so what Barberton actually received was greater than what MSB projected they should get. It appears that MSB is reporting Final Settlement Reimbursement as Total Reimbursement. This leaves the district to believe that MSB can get them more MSP reimbursement than their current billing vendor.

Now let’s move to what MSB says that Barberton can get in MSP reimbursement if “Passage of HB 89”, which is $986,000. Since the Ohio Medicaid School Program is a cost reimbursed program and is based on Actual Costs, Medicaid Eligibility Rate (MER), Random Moment Time Study (RMTS), and the Federal Financial Participation Rate (FFP), this isn’t a number that you can just pull out of the air. MSB has a very unique way of projecting HB 89 MSP reimbursement, which is to multiply what they say you “Should Be Returning Yearly” by 4. That’s right, just multiply an already fabricated amount by 4. I wish it were that easy, but you and I all know that it is not that simple. Below is how MSB computed each district’s potential MSP reimbursement:

Barberton                           $246,500 x 4 = $986,000
Copley-Fairlawn               $39,401 x 4 = $157,604
Coventry Local                  $97,758 x 4 = $391,032
Cuyahoga Falls                  $246,500 x 4 = $986,000 (they show $985,000) minor calculation error
Field Local                           $100,300 x 4 = $401,200
Hudson                                $254,000 x 4 = $1,016,000 (they show $980,000) larger calculation error
Manchester                       $59,500 x 4 = $238,000
Mogadore                           $22,950 x 4 = $91,800
Nordonia Hills                    $130,050 x 4 = $520,200
Norton                                 $50,719 x 4 = $202,876
Springfield                          $144,500 x 4 = $578,000
Stow-Muncie                     $28,603 x 4 = $114,412
Tallmadge                           $104,000 x 4 = $416,000
Woodridge                         $85,000 x 4 = $340,000

For Barberton, this analysis says that if HB 89 would pass and Delegated Nursing and Personal Care Services were added to the MSP program, Barberton’s MSP reimbursement would go from $246,500 to $986,000, for an increase of $739,500. That is totally ridiculous, but unfortunately some districts are buying into this. As we all know, the Ohio Medicaid School Program is a cost reimbursed program and most districts get about 20-30 percent of their Related Service Costs reimbursed in the program. That means that for Barberton to receive an additional $739,500, they would need to have DN and PC aide costs of between $2,465,000 and $3,697,500. These numbers are not just wrong, they are blatantly wrong.

I fully understand that with the financial challenges facing Ohio schools, Superintendents and Treasurers must pursue every dollar they can, but ODE and ODM really need to interject here and make certain that districts are provided with timely and accurate information. I cannot remember when the last time that either of your departments have communicated to provider districts regarding the Ohio Medicaid School Program. This has forced us billing vendors to provide this information to districts, and some have used this void to spread false information in an attempt to get new clients. Regular Medicaid School Program information needs to be sent on a regular basis to all Ohio School Districts as well as Educational Service Centers. ESC’s are not the Certified Medicaid Provider, but they do provide many of the individual therapists and often help coordinate MSP services. Information should be sent to Treasurers, Superintendents, and Directors of Special Education.

I have other concerns such as “MSP Billing Vendor Cost Report Data Manipulation”, but I will cover that in a separate email. I am also concerned that the company that MSB setup called the “Ohio Alliance for Medicaid in Education” (OAME) is claiming that they are an affiliate of the “National Alliance for Medicaid in Education” (NAME). Mark and Yolanda, you are both a member of NAME, as are all the current Ohio billing agents, and OAME is not affiliated with NAME. This is yet another example of misinformation and misrepresentation.

I appreciate all that you can do to educate Ohio school districts on the facts regarding the Ohio Medicaid School Program.

If you have any questions, comments, or need further information, please feel free to contact me.

Respectfully,
Dan Thomas, President
Healthcare Billing Services, Inc.