When a district initially enrolls in the Ohio Medicaid School Program (MSP), the first step is to complete an online “Provider Enrollment Application”. Based on this application, your district is given a State Medicaid Provider Number and an effective date of Medicaid Certification. It sometimes took several months to get certified, but the application process was very basic and required general data like district address, and the Superintendent and Treasurer names.
The Affordable Care Act (ACA), includes provisions that require States to revalidate provider agreements every five years (42 CFR 455.414). This same act requires the States to charge a fee for this re-enrollment, which is currently $553 in Ohio. The Ohio Department of Medicaid re-enrolled one MSP provider school district in 2015, and is scheduled to re-certify another 39 districts in 2016. The re-enrollment process is not overly difficult, but there is one piece of additional data that is now required that many school districts have been reluctant to provide.
42 CFR 455.104(4) requires that the Medicaid re-enrollment data contain “The name, address, date of birth, and Social Security Number of any managing employee of the disclosing entity”.
42 CFR 455.101(c) states that “Managing employee means a general manager, business manager, administrator, director, or other individual who exercises operational or managerial control over, or who directly or indirectly conducts the day-to-day operation of an institution, organization, or agency.”
The Ohio Department of Medicaid (ODM) has defined “Managing Employee” in a school system to be the Superintendent, Treasurer, and the School Board Members. We have enrolled several districts recently and only included the Social Security Numbers of the Treasurer and Superintendent, and they were rejected because we did not report School Board Members. Once the school board member information was provided, the application was approved.
It is important that districts are aware of this issue because it ties in with the ORP/Provider Enrollment issue, and should be included in upcoming discussions with ODE/ODM regarding Physician Prescriptions. It will certainly be an important topic for discussion at the February 25th “MSP Interested Party Meeting”, as Worthington City Schools is first on the list for 2016 MSP Recertification. (Worthington City School’s Medicaid certification expires March 31, 2016). I have attached a list of the MSP school districts that are scheduled for recertification in 2016. You should receive a letter from ODM several months before your revalidation is required.
I have personally lobbied both ODM and ODE many times over the past six months to reconsider whether a School Board Member “conducts the day-to-day operation of an institution”. I have suggested that it is the Superintendent and Treasurer that run the day to day operations of a school district, and that the School Board members only provide “direction and oversite”. ODM has rejected that argument, and currently the Name, Address, DOB, and SS# for all School Board Members are required on all MSP enrollment and re-enrollment applications.