CMS Preps for Upcoming School Year with New Guidance on Leveraging Medicaid to Support School-Based Services

As summer is nearing its end, the Centers for Medicare & Medicaid Services (CMS) is getting a jump on the new school year with a series of announcements aimed at improving children’s physical and mental health. As our colleague Kelly Whitener previewed last week, CMS released a number of Informational Bulletins (CIBs), including two related to the role of Medicaid in supporting school-based services.

The first CIB entitled, “Information on School-Based Services in Medicaid Funding, Documentation and Expanding Services,” reiterates the importance of health services rendered in schools, and provides additional clarity on some of the key aspects of operating school-based health programs and receiving Medicaid reimbursement for covered services. While CMS notes additional guidance is to come as required under the Bipartisan Safer Communities Act, this initial guidance includes a list of nine ways that state Medicaid agencies, school districts, and local education agencies (LEAs) can leverage Medicaid to support their school-based health programs.

For those of you interested in the details, below are highlights from the CIB’s school-based health services checklist:

  1. Adopting the Medicaid “Free Care” Policy: Readers of SayAhhh! are surely familiar with how helpful of a tool the free care rule can be to sustaining school health programs and retaining providers. The CIB encourages states that have not yet taken up the option to expand school Medicaid programs under the free care policy to do so and provides bullet points of helpful reminders for states including that covered services may include but are not limited to EPSDT under federal rules. You can check if your state has taken up the policy option on our State Data Hub.
  2. Outreach, Enrollment, and Care Coordination: CMS emphasizes the importance of enrollment outreach, reminding LEAs that school registration can be an optimal opportunity to help families enroll in coverage such as through Medicaid and CHIP and reminds states that expenditures for such outreach activities can be claimed as costs for administering the Medicaid state plan. It also places focus on “whole child care” and coordination between providers inside and outside schools.
  3. Providing EPSDT Services: CMS encourages states to leverage schools as providers of services in meeting Early and Periodic, Screening, Diagnostic and Treatment (EPSDT) coverage obligations, discusses requirements for participating providers including those in school-based settings, and reminds states that hard, fixed, or arbitrary limits on coverage for services are no permitted.
  4. Medicaid School-Based Services and Managed Care: The CIB provides a number of recommendations for strengthening relationships between managed care and school entities, including developing formal arrangements in managed care contracts to include school-based providers and clinics in network adequacy requirements and facilitating the development of coordinating of care programs between schools and managed care plans.
  5. Telehealth Delivery Systems: CMS encourages states to utilize their existing broad-based telehealth flexibilities to increase access, and reminds states that they are not required to submit a SPA or amendment waiver to pay for services delivered via telehealth if they are made in the same matter as in a face-to-face setting.

The guidance also goes into the weeds on several billing and claiming issues related to Medicaid and schools (more of which is expected to come in future guidance). The four areas included in last week’s CIB are:

  1. Documentation Requirements and Best Practices and Approaches: Here, the CIB specifies the current documentation requirements for services provided in school settings and best practices for meeting those requirements to help with clarity on state provider billing manuals and dispel confusion when it comes time for audits.
  2. Random Moment Time Study (RMTS) Methodologies: States are required to use statistically valid processes to allocate the cost of school-based health services, one of which is a Random Moment in Time Study. The CIB details what states should consider when designing RMTSs, and reminds states that they can utilize other options for cost-based methodologies such as worker day logs and case counts.
  3. Payment Methodology Options: The CIB provides information on options to finance the non-federal share of Medicaid payments, options for paying school-based providers, and reiterates the flexibility that states have to pay school-based providers.
  4. Third-Party Liability: Discusses issues related third-party liability for covered services in IEPs and ISFPs, including state options for seeking reimbursement from a liable third party.

The second CIB published by CMS last week focuses on the USDA Demonstration Project to Evaluate Using Medicaid Eligibility Data to Directly Certify Children for Free and Reduced Price School Meals. This guidance re-ups last year’s round of direct certification demonstrations which we’ve described previously here on Say Ahhh! This demonstration provides state agencies with the opportunity to assess interagency data sharing to reduce administrative burden by directly certifying students for free and reduced-price lunch using Medicaid eligibility.  This latest guidance invites state agencies that administer school meal programs to submit applications to cover project costs for demonstrations during the 2023-2024 school year by September 30, 2022. States selected to participate in previous years’ demonstrations can be found here.

CMS’s recent guidance serves as a helpful reminder of how Medicaid can support school-based services and the key role states, schools, and critical partners can play in making such support a reality.  While we wait for more information on the additional guidance and a new technical assistance center mandated by the Bipartisan Safer Communities Act as well as the new grant funding provided under the law, we will be sure to keep you posted. In the meantime, you can find CMS’s recent CIBs here and here.