05/13/16: ODE State Superintendent

Our New State Superintendent knows all about MSP

By now I am sure that everyone is aware that Paolo DeMaria has been selected as Ohio’s State Superintendent of Public Instruction. I am excited that the position has finally been filled, and even more excited that Paolo was chosen to lead the Ohio Department of Education. I have had the pleasure of working with Paolo during his previous tenure at ODE, and look forward to working with him again. I can honestly say that if it had not been for Paolo, I do not believe that we would currently have an Ohio Medicaid School Program. I am sure that Paolo will have many other important issues to deal with other than MSP, but I am confident that under his leadership, the program will receive the additional resources and attention that it needs.

The Ohio Department of Education is the “Lead Agency” for the Ohio Medicaid School Program, and the Ohio Department of Medicaid is the “Oversight Agency”. With that said, there are many areas in the program that need improvement, and I feel very confident that there will be positive changes made by the new administration. Below are the Top 10 MSP issues (other than ORP) that I will be sharing with our new State Superintendent.

  1. Online Automated Cost Report – This would save a lot of time for everyone involved.
  2. Interim Rate Changes – The online cost report will provide the data needed for rate analysis.
  3. Provider Manual – The program needs a detailed provider manual developed.
  4. Additional ODE Staff – Still only one person to lead a 650 school/$75 million dollar program.
  5. AUP audit changes – We need to strengthen the AUP audit to increase program integrity.
  6. ODE Communication – ODE should provide ongoing timely communication to districts.
  7. Fight for Schools – ODE along with districts should fight against unreasonable mandates.
  8. Program Expansion – Make certain that our program is maximizing Medicaid reimbursement.
  9. Consistency Among Billing Vendors – Make sure that everyone is interpreting the rules correctly.
  10. Monthly MSP Stakeholders Meeting – Begin meeting again on a monthly basis with Stakeholders.

I would like to wish the best of luck to Paolo. He has a challenging task ahead, but I feel confident that he will do a great job for Ohio schools, the children they serve, and the Medicaid School Program.

Healthcare Billing Services, Inc.


05/04/16: Medicaid School Program – Eligible Services

Medicaid School Program – Eligible Services

There still seems to be a lot of misinformation regarding the services that are currently reimbursable in the Ohio Medicaid School Program (MSP). In the attached February 3, 2016 memo from Dr. Sue Zake and Mark Smith, the Ohio Department of Education (ODE) clarified that “There is no change in the services provider districts can claim”. The eligible services include:

  • Audiology
  • Counseling
  • Nursing
  • Occupational Therapy
  • Physical Therapy
  • Psychology
  • Social Work
  • Speech-Language Pathology
  • Targeted Case Management
  • Transportation

This misinformation relates to Delegated Nursing and Personal Care Services, which are not currently reimbursable in Ohio. Some districts are being advised to document for these two services because there will be retroactive billing at a later date. In the attached email, ODE makes it very clear that “there will be no retroactive claims for services not yet available for reimbursement”. There was retroactive billing allowed during the initial startup of the MSP, but that was a result of the CAFS lawsuit settlement. The effective date for any new services will be based on the date that Ohio submits its “State Plan Amendment” (SPA) to the Centers for Medicare and Medicaid Services (CMS). “The Ohio Department of Education will notify provider districts about allowed additional eligible services.”

If and when new services are added to the MSP, all billing vendors will work with their client districts to identify, train, and implement the new services based on the specific rules established by the Ohio Department of Medicaid (ODM) and approved by CMS. Documenting any new services prior to the SPA date will not generate any additional MSP reimbursement. I do not like to see districts go through the effort and expense of documenting services that will not result in Medicaid reimbursement. Please let us know if you have any questions regarding billable MSP services, or “Send questions regarding the content of the ODE memo to SchoolMedicaid@education.ohio.gov.”

Healthcare Billing Services, Inc.



04/22/16: MSP Contract Procurement

MSP Contract Procurement

On April 13th, I participated in a presentation at the OASBO conference regarding the Medicaid School Program (MSP) and the Agreed Upon Procedures (AUP) review. I had the pleasure of presenting with Ken Richards of Kennedy Cottrell Richards (KCR) and Zac Morris with Rea and Associates. We had a lot of information to cover in just one hour of time. As we discussed, the costliest area of exposure in the AUP review relates to “Contract Procurement”. Below is a summary of the Related Service Procurement Requirements for the upcoming 2016/17 school year. Please note these requirements as you are entering into 2016/17 service contracts for MSP therapy services (OT, PT, Speech, Psychology, Social Work, and Nursing).

Contracts over $150,000

  • Must be awarded through full and open competition.
  • Contract file must state rationale for vendor selection. (Cost/Price Analysis)
  • If competition is limited, document your efforts and rationale. (Sole Source Vendor)

Contracts under $150,000, but over the district’s procurement threshold.

  • Documentation must exist that show at least 2 price comparisons, which can be obtained through written, verbal, catalog pricing, internet or from other sources. (Cost/Price Analysis)

Competitive Bidding or Price Analysis are not required for contracts less than the micro purchase limit ($3,000).

Sole Source Vendor

  • Competitive Bidding and/or Price Comparisons are not required if you can justify and you document that there is only one vendor in your area that can meet your service needs. You must document your efforts in determining that the services are “available only from a single source”.

Contracts with ESC’s

  • MSP service contracts with ESC’s can also be designated as a Sole Source Vendor and/or a Shared Services Contract. 45 CFR 92.36 (b)(5) encourages “State and Local intergovernmental agreements for the procurement or use of common goods and services”.

Note, when you contract with two separate vendors for the same service, it is hard to justify that either vendor is a Sole Source Vendor.

Therapy contracts must include the following three statements:

  1. Vendor to comply with the requirements of 45 CFR 164.504(e) (1) for safeguarding and limiting access to information concerning beneficiaries.
  2. The representative of the U.S. Department of Human Services, ODM, ODE or their respective designee will have access to the subcontractor’s books, documents and records.
  3. Vendor acknowledges that they or their principles are not suspended or debarred.

All vendor invoices are required to provide a listing of students served. (It is extremely important that your therapy vendor provide this information for every invoice)


Contracts over $150,000 require Competitive Bidding, unless the contract is with an ESC, or you can justify Sole Source Vendor designation.

Contracts under $150,000 require Price Comparisons, unless ESC contract, Sole Source Vendor, under district’s procurement threshold, or under the Micro Purchase limit.

Include the three statements on therapy contracts.

Require all vendors to provide “Students Served” listing with each invoice.

See Attachment “Medicaid School Program – Contract Procurement Checklist

Healthcare Billing Services, Inc.