RCSD Medicaid compliance officer details $4.9 million reimbursement, flags $1.3 million in missing parental consents and service-order gaps

Mike Salsa, Rochester City School District's Medicaid compliance officer, presented the district's annual Medicaid compliance report at the Board of Education's June 26 business meeting, detailing revenue, compliance gaps and recommended corrective steps.

Salsa reported gross Medicaid revenue for the 2024'025 year of just over $4.9 million, including a $612,000 cost-reporting payment received in May. He said New York's cost-reporting process currently returns about 13% of certain cost-report dollars to districts and that a more equitable share to the district would materially increase revenue.

He identified three primary compliance shortfalls that are costing the district significant recoverable funds. First, parental consent: the district currently has parental consent on file for about 78% of potentially eligible students; roughly 1,092 students (22%) lack a signed one-time Medicaid parental consent form. "We currently right now in the district have 78% of the parental consent, but there still is ... just over a thousand students, with missing parental consent, which is 22%. That's equating to $1,300,000 that we could recoup because it is retroactive," Salsa said. He noted the Medicaid parental-consent form is retroactive and the district is working on a 15-month billing window back to March 2024.

Second, service orders (sometimes called prescriptions): Salsa said therapists and other providers must have timely, correctly completed service orders for related services to be reimbursed, and the district is seeing high rates of late or missing orders. He presented district-level data showing about 15% of service orders were not being written at all and 29% written late, with an average lateness of 50 days; he estimated the current recoverable window for missing or late service orders exceeds $1 million for this school year.

Third, client-identification and matching issues: Salsa said many students cannot be matched to Medicaid eligibility in the state's billing system because of inconsistent identifiers (SIN numbers, prefixes/suffixes, county codes). The district submitted a manual data extract of roughly 600 students to the State for additional matching.

Salsa described steps the Medicaid office is taking: annual and new-staff training for over 500 licensed providers, QR codes and translated consent forms in the top six district languages, a provider help desk, closer work with Child Study/CSC teams and PowerSchool flags showing which students lack consent. He recommended implementing accountability protocols for timely service orders, continued data-matching efforts with the State, and additional staff capacity in the Medicaid office; he noted one recommended hire with Medicaid experience had been cut during the budget process.

Salsa warned of compliance risk: audits or investigations that find unsupported claims could lead to large fines (he cited potential penalties up to $11,000 per claim). He said the Medicaid department regularly pens claims when documentation is incomplete and works proactively to make claims audit-defensible.

Board members asked detailed operational questions. Commissioners discussed ePACES access, provider NPI use, potential use of the Social Care Network/state systems to simplify prescriptions, and whether the Medicaid office could be resourced to pursue recoverable revenue. Salsa said the district's current effort brought $4.9 million this year and, if parental-consent and service-order issues are addressed, the district could reclaim more than $1 million to $2 million in retroactive revenue.

Salsa concluded by urging consistent implementation of consent collection and service-order timeliness to reduce revenue loss and compliance risk.