Author: Dan Thomas

Our Medicaid topic several weeks ago stressed the importance of getting “Signed Parental Consent”, and explained how your Medicaid School Program reimbursement will decrease if a “PR-10 Form” is not obtained for all Medicaid students. A random audit of Parental Consent compliance has now been added to the Agreed Upon Procedures (AUP) audit, and it is very important that districts comply with the Signed Parental Consent and the Parental Notification requirements of the program. Along with the one-time signed consent, the program also requires that an annual MSP Parental Consent Notification be sent to all IEP Students. (See attached Form Letter) Keep in mind that the Medicaid Parental Consent requirements are a mandate from IDEA that has also been adopted in the Medicaid School Program.

The Parental Consent Notification provides parents with the following information:

• Brief description of the Ohio Medicaid School Program.
• Informs parents of their rights under IDEA.
• States that consent is voluntary and can be revoked at any-time.
• Explains that parents will not incur any out-of-pocket costs.
• Provides relevant Federal Code References.
• Asks them to call HBS with any questions.

The notification form can be distributed to parents in any method that you chose, and here are a few examples:

• Mail separately to each IEP parent.
• Include in beginning of the year packets.
• Distribute at each student’s Annual IEP Review.
• Email to each parent.
• Post Notification on school website.

Please inform HBS when and how you distribute the Parental Notification, and we will document your method in our system so it is available in the case of an audit. As you know, audits take place several years later, and we want to make certain that the information is available.

If you have any questions, please let us know.

Beginning with the 2015-16 school year, the Ohio Medicaid School Program will begin to reimburse school districts for “Specialized Transportation” for students on an IEP. Below are the conditions that must be met in order to receive Medicaid reimbursement for this new service.

• Specialized Transportation must be listed on the student’s IEP, and should state the medical reason why the student cannot ride on the standard bus route. Examples:
  • Student requires a wheel chair lift that is not on the standard route bus.
  • Student requires a seat belt or harness that is not on the standard route bus.
  • Student cannot step up onto a standard route bus.
  • Student requires air conditioning which is not on the standard route bus.
  • Student has behavioral issues and cannot ride on a standard route bus.
• Having a bus aide or nurse on the bus does not in itself make the transportation considered “Specialized” for MSP purposes. If a bus aide rides on the regular route, it is not considered MSP Specialized Transportation.
• “MSP Specialized Transportation” means that you have to make a special trip to and from the student’s home to pick them up because there is a medical reason why they cannot ride the regular bus that they would otherwise ride had they not had their medical condition.
• MSP Specialized Transportation can be provided on a School Owned Vehicle or can be provided by a Contracted Transportation Company. Paying the parent to transport the student is not reimbursable under the Ohio Medicaid School Program.
• Each Specialized Transportation trip that the district is seeking reimbursement for must be documented and include:
  • Student Name
  • Dates Transported
  • Signature of Individual Attesting to the Transportation

Documentation can be in the form of a log (attached sample) or invoices from the contracted transportation vendor.

• Send Specialized Transportation documentation to HBS on a monthly basis so that we can process accordingly.
• Transportation can only be billed on days that the student received another billable MSP service such as OT, PT, Speech, Psychology, Nursing, etc.

We are still working with ODE/ODM on the rate methodology, and it appears that we will be using cost data from the ODE T-I/T-II annual reporting to compute a “Rate per Trip” or “Rate per Student” for Cost Reporting purposes.

Please contact our office with any further questions regarding “MSP Specialized Transportation”.

Our first topic, and probably the most important topic, relates to what we call the “Interim Claiming Cost Adjustment”. The Ohio Department of Medicaid (ODM) added language to the MSP rules that reduces overall MSP reimbursement if Medicaid claims are not submitted for all Medicaid students. This means that if your district has 100 IEP Related Service Medicaid students, ODM expects that Interim Claims are submitted for all 100 students. If claims are submitted for only 75 of the 100 students, MSP reimbursement will be reduced by 25%.

The two main reasons why Interim Claims would not be submitted for all Medicaid students are:

• The therapist did not document the service.
• The district did not obtain a signed “MSP Parental Consent Form” (PR-10).

Therapist did not document the service.

All related service therapists (OT, PT, SLP, Psych, Nurse, etc.) must document their ETR Testing and IEP Direct Service for all students. The problem is that many therapists get behind on their documentation and either stop documenting altogether or they miss services or students when trying to catch up at year end. It is extremely important that therapists stay current with their service documentation and document for all services and all students. Quarterly reports are sent to each district that show which therapists are not completing MSP service documentation. It is extremely important that districts follow-up with therapists that are not documenting their MSP services.

Districts did not obtain a signed “MSP Parental Consent Form” (PR-10)

Before Interim Claims can be submitted to Medicaid, the district must have the parent sign the PR-10 form that gives the district permission to share protected health information and bill Medicaid. This form only needs to be obtained one time and is effective as long as the student attends the district. The best time to have this form signed is during the ETR intake process, when the parent is also signing the PR-05 form which gives the district permission to test the student. Quarterly reports are sent to all districts that show students with billable claims that do not have parental consent.

The 2014/15 school year (last year) is the first year that ODM will be making the “Interim Claiming Cost Adjustment”. We have 365 days from the date of service to bill claims, so it is not too late for therapists to catch up on their MSP documentation or obtain signed Parental Consent Forms for last school year. We will continue to send out reports for last school year so that districts can catch up and avoid substantial reductions in their Medicaid reimbursement.