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CMS Releases School-Based Services Guide

  • 1.  CMS Releases School-Based Services Guide

    Posted May 19, 2023 13:38

    As part of the Biden Administration's effort to expand access to Medicaid services in school-based settings, the Centers for Medicare and Medicaid Services (CMS) released Delivering Service in School-Based Settings: A Comprehensive Guide to Medicaid Services and Administrative Claiming.  The guide is a part of the implementation of the Bipartisan Safer Communities Act (BSCA), passed last year, that directs CMS to expand access to Medicaid health care services, including behavioral health services, in schools. 

    In the guide, CMS and the Department of Education (ED) acknowledge the current administrative burden on schools seeking payment for Medicaid and Children's Health Insurance Program (CHIP) services.  In addition, they acknowledge that a "school setting offers a unique opportunity to enroll eligible students in Medicaid or CHIP; facilitate access to coverage; and provide health services directly to Medicaid and CHIP beneficiaries who are students."  In response, the guide grants additional flexibilities to states allowing them to adjust their individual Medicaid state plans expanding access to school-based services and decreasing administrative burden for school-based health care service providers and local educational agencies (LEA).  New billing and payment flexibilities include:

    Roster Billing;

    • Per Child, Per Month (PCPM) or Per Service, Per Month Rate;
    • Option to Not Submit Bills for Each Service;
    • Fee Schedule Rates that Exceed the Community Rate;

    The guide provides additional flexibilities that focus on documentation, allocations to Medicaid, time studies, provider qualifications, and third-party liability that also aim to reduce administrative burden for school-based services and provide schools and LEAs the ability to provide more accessible care.  Additional information on the new flexibilities can be found in the full guide.

    While the guide grants additional Medicaid flexibilities, individual states will still need to change their Medicaid plan with the federal government through a state plan amendment (SPA), which must be first agreed upon by the state legislature.

    ED and CMS will hold a stakeholder call regarding the guide on May 22 from 3:30-4:00 EST.  Leaders from the education, health, and disability communities are invited to join the call to discuss the potential impacts of the new flexibilities on school-based health providers.  Interested parties can register here.


    Otto Katt
    Lewis-Burke Associates
    Washington DC