The School Health and Related Services (SHARS) billing process in Texas is undergoing significant changes that will require school districts to reassess how they handle reimbursements. These adjustments come with stricter policies and guidelines, aimed at improving accuracy and reducing errors in claims. As these changes are implemented, it is critical for Texas districts to stay up-to-date with the latest requirements to avoid financial losses and audits.
Key Changes to Texas SHARS Billing
The Texas SHARS (School Health and Related Services) billing system has undergone significant updates, and it is essential for districts to stay informed about these changes to ensure compliance and maximize reimbursements. The following are key updates that could directly impact how services are billed and tracked, with a focus on personal care services (PCS), IEP services, and the increased risk of audits.
1. Tougher Rules for Personal Care Services (PCS) Claims
The Texas SHARS (School Health and Related Services) billing system has undergone significant updates, and it is essential for districts to stay informed about these changes to ensure compliance and maximize reimbursements. The following are key updates that could directly impact how services are billed and tracked, with a focus on personal care services (PCS), IEP services, and the increased risk of audits.
One of the most impactful changes to SHARS billing is the tightening of PCS reimbursement guidelines. TMHP now requires more detailed documentation to prove that services are medically necessary. Previously, PCS could be provided to students who needed assistance with activities due to behavioral concerns alone. Now, the need for PCS must be directly tied to a medical condition that impacts the child’s ability to perform ADLs/IADLs safely and effectively. This means that services previously considered eligible for reimbursement may no longer qualify, leading to a reduction in the total amount districts can claim for PCS.
Another significant change with PCS is the documentation requirements that all services must be documented individually for each student, rather than allowing group documentation. Prior, providers could document PCS services in a group format, meaning a single note could cover multiple students receiving similar services at the same time. Now, each student’s PCS services must be documented individually, with specific details about the support provided to that student. Group documentation is no longer allowed for Medicaid reimbursement. This change will require providers to spend additional time documenting PCS services individually for each student, increasing their workload compared to the previous group documentation method.
It’s essential that districts streamline their PCS documentation processes to ensure that only eligible services are claimed. Lack of specific documentation or poor tracking of service delivery could lead to fewer approved claims, ultimately impacting the district’s funding.
2. Increased Scrutiny on IEP Services and Cost Reporting
In addition to the changes in PCS billing, districts must now be more diligent in tracking and documenting services provided under students’ Individualized Education Programs (IEPs). With increased scrutiny on cost reporting, districts are expected to report only services actually delivered to students. Any discrepancies between services prescribed and services delivered could lead to reduced reimbursements or even audits.
For accurate reporting, school districts should ensure that their records for services such as Occupational Therapy (OT), Physical Therapy (PT), and Speech Therapy are in perfect alignment with the IEPs, so they can maximize their reimbursement potential.
3. Higher Risk of Audits and Paybacks
The SHARS program is now more focused on identifying discrepancies between Fee-for-Service (FFS) claims and cost reports. Districts with a large gap between these two figures are at a higher risk of being audited. Audits can result in financial penalties, including having to repay funds to the state. Districts should work to ensure that their SHARS claims and cost reports are consistent and thoroughly documented.
What Districts Need to Do to Stay Compliant
With these changes in mind, it can feel overwhelming for school districts and might even lead to questions about the future of their SHARS billing. While the changes to PCS will lead to reductions in revenue, it doesn’t mean that all is lost. The districts who can adjust their internal processes to meet the updated SHARS requirements will be able to minimize the loss from PCS reimbursements. Here are some actionable steps:
1. Simplify PCS Documentation
To avoid confusion and reduce errors, district leaders should implement a clear and efficient process for documenting PCS services. There has been much confusion from districts in the state as to what exactly is required for documenting PCS services. An overly complicated process can put significant strain on staff which leads to delays in submitting accurate logs, resulting in fewer claims. Streamlining documentation ensures that services are tracked effectively, which will lead to more claims being approved and higher reimbursement rates.
2. Strengthen Oversight of Therapy Services
Therapy services, including OT, PT, and Speech, are critical to the SHARS billing process. Districts must ensure that the number of prescribed minutes aligns with the services actually delivered to students. Accurate tracking and documentation of therapy services will not only lead to more FFS reimbursements but will also ensure that IEP ratios are in compliance for cost reporting analysis.
Aligning with Updated SHARS Compliance Standards
The changes to Texas SHARS billing may seem daunting, but with the right approach, districts can continue to benefit from Medicaid reimbursements. By simplifying documentation processes, strengthening oversight of therapy services, and staying proactive about compliance, school districts can avoid audit risks and maximize their reimbursements. Accurate reporting and alignment with updated SHARS policies will be crucial in the coming months as districts navigate these changes.
Interested in finding out how to start incorporating these services into your district Medicaid program? Reach out to Relay—your School Medicaid Billing Software specialists.