Many of you called for help, and OSSPEAC responded!
Changes in the Medicaid Schools Program have been happening very quickly. Late last school year, there was concern that school-based related services would have to be prescribed by a physician in order to be billable to Medicaid. The Government Affairs Coalition (the speech and hearing legislative group for Ohio) went into action, and this provision was changed, allowing school-based SLPs and audiologists to by-pass the prescription requirement IF they registered as Independent Providers. Right at the end of the school year, many school billing entities and districts were requiring professionals to complete this process as quickly as possible.
While it did solve the physician referral issue, the application process raised additional concerns, specifically that it appeared to require SLPs and audiologists to declare that they were sole proprietors of a solo practice who would be receiving reimbursement for services, which does not describe school-based practice is most cases. Understanding this to be an ethical issue of concern to our members, OSSPEAC Board members, completing this process alongside the membership, took screenshots of the online form, using them as illustrations of the difficulties faced in completing the form and included them in a letter directed to the Ohio Board of Speech-Language Pathology and Audiology (OBSLPA) for clarification of the potential ethical issues involved.
Gregg Thornton, Executive Director of the OBSLPA, responded at once to clarify these issues. His letter to the OSSPEAC Board is summarized below:
- Because there are no alternatives offered by MSP that would allow SLPs and Auds to make “referrals” (required in the Medicaid process) other than Independent Provider, this designation would NOT be considered misrepresentation under the Board’s Code of Ethics.
- The 1099 and W-9 form filing required for Medicaid will not be used for billing purposes, but rather simply to verify the identity of the professional, so filing these forms (usually associated with reimbursement of a professional for services rendered) would also NOT be considered misrepresentation under the Board’s Code of Ethics.
- Designating the group affiliation would also NOT be considered misrepresentation under the Board’s Code of Ethics.
In other words, as long as school-based SLPs and audiologists follow the instructions given by the Ohio Department of Medicaid and the Medicaid Schools Program when completing the Medicaid application process, they will be meeting the licensure Board’s Code of Ethics.
OSSPEAC and GAC continue to follow this issue closely, and will keep you updated as further information becomes available.