If SBS are excluded from a state’s managed care delivery system and covered under an FFS delivery system, the claims must be submitted directly to the state’s Medicaid FFS program. As page 45 of the Comprehensive Guide describes, under an FFS delivery system, "providers submit claims for the services that they provide to the State Medicaid agency through billing systems and receive payments at the applicable fee schedule rate for a service."
LEAs and school-based providers must only contract with MCPs to become network providers if the state includes SBS in a managed care delivery system. However, regardless of whether SBS are included in managed care, there are several regulations on the coordination of care, and states and MCPs should coordinate with LEAs as necessary. For example, 42 CFR 438.208(b)(2) requires that MCPs coordinate services covered by the MCP with services that their enrollees receive through FFS or other MCPs; the services provided through FFS or another MCP could include services delivered in schools.