Documentation audits seem to be the new norm in healthcare, and public schools participating in Medicaid claiming are likely no exception. Although Medicaid hasn’t yet expanded its audits in this area, it is a possibility this can occur in the future.

According to a September 2015 report published by the Office of Inspector General, two Massachusetts school districts received overpayments due to cost reporting errors in FY 2012. The state Medicaid agency was required to refund thousands of dollars as a result of the investigation.

Going forward, state Medicaid agencies will probably keep closer tabs on public school-based Medicaid claiming programs. Medicaid wants to ensure that schools participating in these programs provide documented records of all Medicaid services that various school health personnel render. Schools must complete this documentation to receive reimbursement for all Special Education health-related Medicaid-covered services provided to Medicaid-eligible children. Services include speech therapy, occupational therapy, physical therapy, audiology services, counseling, nursing services, personal care, behavioral health, and applied behavior analysis (ABA).

If the documentation is omitted—or it doesn’t support the services billed—the school, state Medicaid agency, and/or the municipality in which the school is located could be required to refund the payment. It’s important for school personnel to understand their responsibilities in terms of providing clear and detailed documentation.

4 tips to secure compliant documentation

Consider these four tips to capture documentation most effectively:

  1. Remind personnel to document each time a Medicaid-covered service is provided to a student.
  2. Reiterate the importance of documentation. Although documenting services may take time and effort, the documentation is a critical part of compliance—and it could protect the school and municipality during an audit.
  3. Ensure that the documentation includes the following elements: School district name/provider number, student name, student date of birth, student Medicaid number, date of service, activity/procedure note (including whether the activity/procedure was performed individually or as part of a group), service time, and signatures. In the event of an audit, documenting the activity/procedure as ‘speech therapy’ is not advisable. Instead, encourage providers to document ‘Working with a student related to articulation of the ‘th’ sound for 20 minutes.’
  4. Don’t forget about ABA therapists. In July 2014, Medicaid announced it would begin to cover medically necessary treatment for autism, including ABA. It’s important to capture all documentation for ABA services rendered to Medicaid-eligible students.


Choose your billing vendor carefully

When evaluation third-party billing companies that will perform your Medicaid claiming, be sure to ask the following questions:

  • Can the vendor integrate with the school’s record system to access documentation easily and streamline processes?
  • Is the vendor willing and able to collaborate with information management solutions to develop an electronic system of tracking Medicaid billable hours?
  • Does the vendor review provider documentation to confirm that all required and relevant service data components are present?
  • Does the vendor have access to—and review—all individualized education programs (IEP) to compile a list of missing documentation for each student?
  • Can the vendor assist with obtaining, validating, and tracking parental authorization for Medicaid billing? Can it also assist with RMTS monitoring?
  • Is the vendor able to validate student and provider eligibility?

To learn more about compliant Public School-Based Medicaid Claiming, call Jennifer White at NEMB at 508-297-2068 x233


About NEMB

New England Medical Billing is a fully HIPAA compliant Medical Billing Management and Administrative Service Firm. Our expertise is in program and system design as well as effective implementation and administration. Our multi-disciplinary approach and attention to detail consistently yields the maximum allowable returns on every client project.

Since 1993 NEMB has been built carefully, approaching each new engagement using proven management methods. Our superior, time-tested approach is applied to each and every engagement. We “zero-base” every new proposal to build a process that fulfills the unique requirements and goals of each project.

Our billing administration experience in ambulance & EMS services, emergency departments, school-based Medicaid claiming and private physician practices has honed and streamlined our clients’ operations in capturing and maximizing revenue opportunities on a large scale.


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