The Ohio Department of Education (ODE) continues to closely monitor the status of the state’s compliance efforts in meeting new mandates concerning Ordering, Referring and Prescribing (ORP) provider requirements for Medicaid Schools Program (MSP) therapy service reimbursements. This issue is particularly important, as failure to adhere to the changes could result in serious implications concerning the district’s reimbursements and their ability to deliver seamless special education services moving forward. In fact, during a recent webcast, the Departments of Medicaid and Education reported that if the state is unable to comply, individualized education program (IEP) service claims would be deferred, ultimately disallowing Federal Financial Participation (FFP).
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The Centers for Medicare and Medicaid Services (CMS) states that, to be covered by Medicaid, all physical therapy occupational therapy or speech pathology and audiology services must be prescribed or referred by a physician or other licensed practitioner (ORP). Additionally, claims without an appropriate prescription or referral will no longer comply with federal regulations.
According to a memo from ODE, CMS requested Ohio to submit its plan to address the compliance issue. At this time, there has been no formal reply from CMS with regard to the state’s proposed plan.
The Ohio School Health Services Association (OSHSA) hopes an extension will be granted through June 30, 2017, which would give ODE the time needed to make the necessary changes while avoiding interruptions to the programming. In addition, there have been collaborative efforts through Sub. H.B. No. 89 to address ORP issues looming over the program.
In the meantime, ODE advised MSP providers throughout the state to continue documenting services rendered and evaluations as usual. The agency went on to state that upon receiving a reply CMS’s reply “next steps and any necessary program or documentation changes” will be communicated.
Additionally, school districts should also be aware of agreed upon procedure updates currently being enforced by Ohio’s MSP. Specifically:
- The district’s responsibility to verify that a parental consent form is on file for the student identified on the paid claim. If a parental consent form could not be obtained, a proposed cost adjustment for the claim amount must be prepared using Schedule P.
- The acceptance of flat fees.
- A procurement threshold increase for the purpose of mirroring the uniformed guidance of $150,000 for direct medical service contracts.
- Updates to testing procedures for shared service agreements and private vendors, Including:
- Procedures for assessment or reassessment of the covered population.
- The identification of service types and whether they are allowable.
- The cost to be charged and the basis for the charge.
- The addition of a purchased services schedule to the cost report.
- New exceptions with regard to requiring price and rate quotes.
By Zac Morris, CPA (Millersburg office)