DHCS Posts PPL 19-015, Notification of Change to Physician Prescription Policy

On July 10, 2019, DHCS posted Policy and Procedure Letter (PPL) 19-015 stating that for services dated July 1, 2019, and forward, treatment authorizations (orders/prescriptions) signed by Physician Assistants (“PA”) or Nurse Practitioners (“NP”) are eligible. This means, for example, that the specialized procedure orders that in the past met the criteria but were signed by a PA or NP rather than the physician, may now qualify—this is good news for California LEAs!

As expected, there is a bit more to it that is critical to highlight:

  • The PA or NP must have authority delegated to them by the supervising physician, and
  • Both the supervising physician and the PA or NP need to be enrolled as Medi-Cal providers

For easy reference, the below chart reflects what has changed:

Treatment Authorization Who?
Medication and Therapeutic Agent Administration, and Specialized Healthcare Procedures Physician’s order Student’s Physician (or delegated PA or NP)
Speech & Audiology Treatments Physician-approved standards for referral to service (i.e., “speech and audio protocol”)* LEA’s contracted physician
OT/PT Treatments Physician’s prescription LEA’s contracted physician or student’s physician (or delegated PA or NP)
Mental Health Treatments Referral for treatment Physician (or delegated PA or NP), licensed mental health practitioner, or RCSN

The primary impact point of this policy change is going to be the nursing/health aide treatment orders (or, specialized procedures).

The providers can be employed or contracted by the LEA or be the student’s primary care provider. As with all other LEA authorizations, they need to comply with the Medi-Cal Ordering, Referring and Prescribing (ORP) provider policy (PPL 18-018R) to bill Medi-Cal.