Question Billing IEP Services to Medicaid


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I am billing IEP school based health services to Medicaid for my local school district in VT. At the start of this school year, special educators worked with parents and the IEP team to develop 3 IEP service pages to reflect what and how services would be delivered under 3 general educational models (fully in person, fully remote and hybrid). The hybrid model involves some in school education and some days accessing general educationand/or SPED services on a virtual platform such as Zoom, Skype or Google. Because of the challenges that some of our students face accessing curriculum and services on a virtual platform, they may receive their special education services in person, regardless of the general educational model that they are participating in. This means that a student's current general education model might be fully remote, but they may be receiving in person special education services either in their home or by going in to the school for specific services, but their general education curriculum is still fully accessed on a remote platform.
What are your thoughts on billing for in person IEP services when the students general educational model is fully remote? I am told that if students are "fully remote" then we can't bill for in person services, even if special education services are listed as being in person under a fully remote general education model on the IEP. Essentially, that if the student is "fully remote" then in person special education services would not be billable in that general education service model because the overarching general education service model is fully remote and as such, in person services would not be allowed to be billed to Medicaid.
Thank you for your input!
Jayne Tessitore, CPC