In our field, billing for insurance and medicaid is a necessary evil (it seems).
Recently, on the ASHA community page someone commented about billing for medicaid. I’ve heard the discussion before, and it was definitely one of the things I’ve asked about in interviews…but there’s two very different sides. I’d love your opinion on each side.
Side 1: Whether or not someone is on medicaid is too confidential for the SLP. Therefore, an outside entity (usually the billing company) has to do the medicaid filing. Therefore, the SLP must submit billing for each and every student on his/her caseload, submit it to the billing entity, who in turn actually bills medicaid. I’m sure there’s a wonderful little fee associated with such transactions, but no one ever talks about that.
I have a couple of issues with this.
FERPA…and/or HIPAA. According to the US Dept. of Education the only individuals with whom a school record can be shared legally is:
- School officials with legitimate educational interest;
- Other schools to which a student is transferring;
- Specified officials for audit or evaluation purposes;
- Appropriate parties in connection with financial aid to a student;
- Organizations conducting certain studies for or on behalf of the school;
- Accrediting organizations;
- To comply with a judicial order or lawfully issued subpoena;
- Appropriate officials in cases of health and safety emergencies; and
- State and local authorities, within a juvenile justice system, pursuant to specific State law.
Now, I don’t know about you, but I can’t find Medicaid billing entity on that list anywhere. It’s certainly not in the “appropriate parties in connection with financial aid to a student” because every student is entitled to a Free and Appropriate Public Education and doesn’t pay for school services (that is more for colleges/universities). Medicaid billing certainly isn’t a study (although, I suppose it could be one…. how many hours of useless Medicaid billing does it take before the SLP throws her hands up in disgusts and quits?).
The second issue is Workload. Many SLPs, have upwards to 80 – 100 students on their caseload. Of those, let’s say as many as 50% are Medicaid eligible. That’s a huge inflation. Unless it’s an inner city extremely poor school district, it won’t be that many (particularly since the entity has to receive permission from the parents to bill, have Medicaid numbers, and doctors prescriptions saying it’s necessary and we know how that flow of information typically goes).
Now to bill for Medicaid, each district is different. (Honestly, I’m not sure if it’s a district thing, or a state thing. Once again, here in my district we are doing things RIGHT as it is easy and not time-consuming!) Typically at the very least, you have to document the date, number of students who attended (individual, group) and length of session. Some districts require SOAP notes to include growth, percentages, activities, etc. So actual time spent billing could be as small as 2 minutes per kid to as long as 5-10 min per kid (per week). Oh, and don’t forget that if there’s an SLPA or another SLP who isn’t able to sign off on Medicaid, then the SLP that IS able to has to do file reviews and bill for those students as well even though she doesn’t actually SEE those students (talk about having faith! My license on the line in the hopes that someone else is doing what they’re supposed to be doing and not committing fraud???).
So…now let’s figure out Medicaid billing for someone who has to submit billing for every student. Hmmm. 80 x 2 = 160/week, 80 x 5 = 400 minutes/week.
400 minutes = that is 6.6 HOURS of Medicaid billing…at least 50% of it which is NOT NEEDED because the kid is not on Medicaid. What could we do with 3-6 hours of paperwork time each week? (I know…maybe not take work home where we work for countless hours for free?)
So, the SLP (OT/PT too) are supposed to spend an extra 3 hours a week doing paperwork that is useless all because it’s too confidential to know who is on Medicaid? But it’s okay for a Medicaid billing company to get paid for knowing who is receiving school-based speech services (even though it’s a violation of true FERPA)? How does THAT work?
Side 2: The SLP is responsible for getting the Medicaid permission forms filled out and only bills for the students they see who are actually RECEIVING Medicaid (novel idea, right?). The SLP has the same responsibilities, but only bills for those who qualify.
So… let’s say 40 kids (80 on caseload) x 2 = 80 minutes every week spent on billing… Oh, and if we say 40 x 5 = 200 minutes/week billing. This equals to 3.3 hours of billing time (which is still a lot, but at least it’s for a reason since supposedly the schools receive the money).
The most common reason that I’ve heard for billing everyone, is because schools are afraid of being accused of providing more services for students who are Medicaid eligible in order to get more Medicaid money.
This really is an interesting tangle. Are we, by allowing an outside agency to have access to IEP information violating FERPA? Could we be liable for misuse of that information? If, for some reason, there is a Medicaid billing error who is liable? The SLP who signed off on the information or the Medicaid billing company?
We won’t even get into the whole education vs medical conundrum because that would be an entirely different post.
So…let me know. Do you bill for Medicaid? How many minutes/hours per week does it take you to do so? Do you bill for your entire caseload or only those who are Medicaid eligible? There is obviously some rationale I’m missing, what is it? Leave me a note here, I’d love to hear how it works in other areas besides my little utopia.
Until then…Adventure on!