Medicaid School-Based Services Although there has been much attention focused on Medicaid services provided in the schools, especially from the U.S. Department of Health and Human Services’ Office of Inspector General (OIG), the Centers for Medicare and Medicaid Services (CMS) does not anticipate publishing an updated version of its 1997 Medicaid and School ... Bottom Line
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Bottom Line  |   September 01, 2003
Medicaid School-Based Services
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School-Based Settings / Practice Management / Bottom Line
Bottom Line   |   September 01, 2003
Medicaid School-Based Services
The ASHA Leader, September 2003, Vol. 8, 3-31. doi:10.1044/leader.BML.08172003.3
The ASHA Leader, September 2003, Vol. 8, 3-31. doi:10.1044/leader.BML.08172003.3
Although there has been much attention focused on Medicaid services provided in the schools, especially from the U.S. Department of Health and Human Services’ Office of Inspector General (OIG), the Centers for Medicare and Medicaid Services (CMS) does not anticipate publishing an updated version of its 1997 Medicaid and School Health Technical Assistance Guide.
Since Medicaid is a jointly funded program between the federal government and the states, CMS allows states considerable flexibility in administering the Medicaid program, including school-based services. That being said, there are specific CMS guidelines school administrations must adhere to in order to qualify for reimbursement. One of these guidelines addresses the need for speech-language pathology and audiology services to be provided by qualified providers or under their direction. Unfortunately, until recently, CMS had not provided states with specific guidance on what constitutes “under the direction of,” allowing the states great flexibility in interpreting this requirement.
In April, CMS provided interpretive language on this issue as part of a proposed rule on Medicaid provider qualifications for audiologists. In the proposed rule, CMS states that the qualified person must supervise each beneficiary’s care. In supervising the care, CMS indicated that the audiologist must see the beneficiary initially, prescribe the type of care provided, and review the need for continued services throughout treatment. CMS also indicated that the audiologist must assume professional responsibility for the services provided and ensure that the services are medically necessary. The concept of professional responsibility implicitly supports face-to-face contact by the audiologist, at least at the beginning of treatment and periodically thereafter. CMS expects that documentation must be kept supporting the supervision of services and the audiologist’s ongoing involvement in the treatment.
While this is only interpretative guidance and is not part of the regulations governing Medicaid speech-language pathology and audiology services, ASHA is working with CMS to ensure that state agencies, to the extent feasible under Medicaid laws, adhere to the guidance provided by CMS. ASHA also is working to strengthen the “under the direction of” language in the proposed rule to address issues regarding appropriate supervision ratios, education of nonskilled providers in providing covered services, and a means for unskilled providers to have immediate contact with qualified providers in case of emergency.
In working with administrators, speech-language pathologists and audiologists should use the CMS proposal [PDF] as a basis for discussions on their supervisory role. In August 2001, a then-Health Care Financing Administration regional office provided its interpretation of “under the direction of” in Program Issuance MCD-22-95 to its regional carriers and intermediaries. This issuance indicated that an SLP or audiologist is ultimately responsible for the actions of the personnel they sign-off on.
In addition, the OIG has published a number of reports on inappropriate billing of services by school systems. The reports provide excellent insight into the type of practices that the OIG found questionable and also can be a useful tool in negotiations with school administrators. These reports will be made available in the near future on ASHA’s reimbursement Web site. In addition, through its focused initiative on reimbursement, ASHA is developing additional guidance on this issue, which should be available to members by the end of the year.
If you have any questions regarding Medicaid coverage of school-based speech-language pathology and/or audiology services, contact Ingrida Lusis through the Action Center at 800-498-2071, ext. 4482, or via e-mail at ilusis@asha.org.
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September 2003
Volume 8, Issue 17