It’s Here! An Introduction to the Much-Anticipated Updated School-Based Medicaid Services and Administrative Claiming Guide

May is Mental Health Awareness Month, and last week’s news takes this month to heart with the release of the much-awaited Comprehensive Guide to Medicaid Services and Administrative Claiming by the Centers for Medicare & Medicaid Services (CMS) in consultation with the US Department of Education (ED).

The first comprehensive update in two decades, CMS’s release of the guide makes good on the mandates set forth in the Bipartisan Safer Communities Act requiring updates to the 2003 School-based Administrative Claiming Guide and 1997 School-Based Services Technical Review Guide. The updated comprehensive guide clarifies and consolidates the policies put forth in the 1997 and 2003 guidance, and expands the flexibilities that states have to streamline administrative claiming for school-based Medicaid services. The whopping 184 page guide and accompanying Informational Bulletin also released today elaborates on the guidance issued by CMS last August and covers a variety of issues  from billing processes to best practice for enrolling qualified care health providers to parental consent including a series of new flexibilities.

While we dig deeper into the guide, some highlights of the flexibilities and topics covered include:

  • New flexibilities for billing and payment methodologies intended to reduce administrative burden on schools.
  • Opportunities for streamlined processes for local education agencies and school-based providers to provide documentation for claims.
  • Revamping time study requirements to ease school administrative burden on states and school districts.
  • Best practices for enrolling qualified providers and recognizing an array of school-based and non-school based providers to help maximize beneficiary access to Medicaid services.
  • New options around third party liability when recovery is not cost effective.

In addition to the new options the states can take up, the guide also reinforces the scope of Medicaid services provided in schools, including encouraging states to expand reimbursement of these services to students that don’t have an Individualized Education Program (IEP), discusses the delivery of these services through avenues such as managed care and telehealth, and provides insight into the interaction between CHIP and school-based health services.

On top of the guidance, CMS announced that New Mexico and Oregon received approvals to expand their school Medicaid programs to provide reimbursement for services delivered to students regardless of having an IEP – visit our State Data Hub to view if your state is among the ranks of New Mexico and Oregon. At the same time, the Department of Education also released a NPRM that would simplify the process for gaining parental consent when billing for Medicaid services through a student’s IEP

The flurry of activity on expanding access to Medicaid services for students, including mental health services, is of particular relevance given the ongoing youth mental health crisis and CDC data finding more than four in ten students felt persistently sad or hopeless.

While we celebrate the work that has already been put into the sustainability of school health programs through the use of Medicaid, we are looking forward to what is to come with the pending Technical Assistance Center and $50 million in grants to help states implement the flexibilities offered in the guide also mandated under the Bipartisan Safer Communities Act.

For additional information on the guide, see the factsheet and related Informational Bulletin.