NY

Document ID: CMS-2009-0037-0011
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: May 07 2009, at 02:14 PM Eastern Daylight Time
Date Posted: May 13 2009, at 12:00 AM Eastern Standard Time
Comment Start Date: May 1 2009, at 05:12 PM Eastern Standard Time
Comment Due Date: June 1 2009, at 11:59 PM Eastern Standard Time
Tracking Number: 8097bb41
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This is comment on Proposed Rule

Medicaid Program: Rescission of School-Based Services Final Rule, Outpatient Services Definition Final Rule, and Partial Rescission of Case Management Services Interim Final Rule

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While we support Medicaid funding for most special education ancillary services such as OT, PT and speech therapy we oppose Medicaid funding for Targeted Case Management (TCM). The purpose of TCM is to represent the best interest of the client. School district personnel often find themselves representing the best interest of the school district and not the client (student). While we see a real need for TCM, we believe that this provision of service must be done by someone other than the school district. We provide special education advocacy on behalf of approximately 1000 students per year along with their families and find it difficult to understand why a school district is receiving Medicaid funding to advocate against the best interest of their students.