DOE NPI & Medicaid Enrollment Consultation Information
July 19, 2019
What's happening now? After consultation with our Union and a small pilot project with six affected employees, the State Department of Education is moving forward with requiring National Provider Identifier numbers and Medicaid enrollment for all DOE employees who are licensed health care providers.
The DOE rejected our requests that NPI numbers and Medicaid enrollment be done on a voluntary basis until the department has more experience in the process and the opportunity to assess and evaluate the outcomes of the reimbursement requests.
What was the Pilot Project? On July 16, 2019 HGEA and DOE met to discuss the results.
NPI/Med-QUEST Pilot Program. Here's what we learned:
Six affected employees participated in the pilot program, acquiring an NPI number and enrolling with Med-QUEST.
The pilot period was from the end of April 2019 until the end of last school year; approximately 4-5 weeks.
Services provided by these employees during that time were submitted using the DOE’s NPI number along with the NPI number of the pilot participant.
The DOE will find out in August what the Medicaid reimbursement will be for the services that were provided during the pilot period.
Based on the survey results (5 of the 6 employees participated in the survey), all of the participants responded 'No’ to the following questions:
• Was there a change in the method of delivery for services rendered to students?
• Was there any change in the scope, frequency, or duration of the services rendered to students?
• Was there any change in the methodology for documentation or record keeping?
• Have there been any changes to the time spent documenting your work?
• Has there been any change to your daily/weekly routine?
• Are you doing any work now that you were not required to do before?
Personal Liability Concerns
DOE reconfirmed to HGEA that the processes currently in place to document and report services provided will be the same with the exception of including one’s NPI number. The department and license standards that the affected employees are held to will not change as a result of the NPI and Medicaid enrollment.
Use of the NPI Number
The DOE reiterated that they will continue to use the Department’s organizational NPI number for billed services. However, in order to obtain a reimbursement from Medicaid for eligible services, the DOE must include the NPI number of the employee who provided the services. Centers for Medicaid & Medicare Services require that all licensed health care providers have an individual NPI number and be enrolled in Medicaid.
Exposure of Personal Information
For the upcoming sign-up sessions, affected employees will be allowed to use a DOE address (to be shared at the sessions) when applying for an NPI number instead of their home or personal mailing address. This is to address the concern that employees’ personal address can be accessed by simply searching an employee’s name along with ‘National Provider Identifier or NPI number. This does not apply to those who use or will use the NPI number for personal business purposes.
DOE confirmed that any inquiries from Medicaid would be directed to the department and not to the employee/licensed health care provider. If information is needed from the employee regarding any services that were provided, that request or directive will come from the DOE.
Partnership with the University of Massachusetts (UMass) Medical School
DOE reiterated the role of the University of Massachusetts (UMass) Medical School as the department’s 3rd party biller to assist the DOE with the submission of Medicaid claims electronically. The DOE Office of Student Support Services (OSSS) is responsible for billing for Medicaid reimbursement. Information entered into the Electronic Comprehensive Student Support Systems (eCSSS) is electronically transferred to UMass. The department shared that UMass works in this capacity with school districts in approximately 13 states.
Sign-up sessions are being scheduled statewide and HGEA is invited to attend. As of July 16, 2019, some dates/times have not been confirmed. DOE will notify and provide HGEA with a copy of the schedule when it is finalized. During these sign-up sessions, HGEA has requested that the DOE provide an explanation of the process that will occur after information regarding services provided is documented using Electronic Comprehensive Student Support Systems (eCSSS).
Based on what has transpired since January 2019, the DOE has met their obligation to engage in full and meaningful consultation and we will notify the department accordingly. The DOE has responded to our questions which is the requirement. That doesn’t necessarily mean that we agree with all the responses or believe that all of our questions and concerns have been adequately addressed.
The DOE says it is open to meet and discuss unforeseen issues or concerns that may arise as they move forward with this new process. It is HGEA’s expectation that the DOE will revisit issues or concerns already raised if it turns out that the responses provided by the department are not accurate or complete.
HGEA will continue to stand with our members and bring your concerns to the DOE as the process rolls out and implementation begins.