May an LEA claim for administrative activities if it does not also provide direct services to Medicaid-eligible students?

There is no prohibition on claiming for administrative activities if the LEA does not also provide direct services. LEAs may choose to participate in only administrative activities, only direct services, or both administrative and direct services.

An LEA can claim the full scope of administrative activities without providing proof of a paid service. Please see Example 3 on page 27 of the Comprehensive Guide:

• Example 3. The school is not a participating provider. The school program refers Medicaid-eligible children to participating Medicaid providers in the community. If the school performs administrative activities related to the services billed to Medicaid by community providers, the costs of such activities are allowable under the Medicaid program. Such activities would be reported under the appropriate Medicaid-related activity code.