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Frequently Asked Questions

Frequently Asked Questions are used to provide additional information and/or statutory guidance not found in State Medicaid Director Letters, State Health Official Letters, or CMCS Informational Bulletins. The different sets of FAQs as originally released can be accessed below.

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Are LEAs permitted to request reimbursement for parents who transport their child with a disability to school in a specially adapted vehicle, provided that specialized transportation is outlined in their child's IEP?

Yes, provided the following conditions are met. As noted on page 99 of the 2023 Comprehensive Guide to Medicaid Services and Administrative Claiming under section G. Special Considerations for Transportation and Vaccines as SBS:

“School-based specialized transportation is defined as transportation to a medically necessary service (as outlined in the IEP of an enrolled Medicaid beneficiary) provided in a specially adapted vehicle that has been physically adjusted or designed to meet the needs of the individual student under IDEA (e.g., special harnesses, wheelchair lifts, ramps, specialized environmental controls, etc.) to accommodate students with disabilities in the school-based setting. Note: the presence of only an aide (on a non-adapted bus/vehicle) or simple seat belts do not make a vehicle specially adapted. Specialized transportation may consist of a specially modified, physically adapted school bus or other vehicle in the specialized transportation cost pool.” 

Under the Individuals with Disabilities Education Act (IDEA), if a child with a disability is receiving special education and related services, transportation is included in the child’s IEP, and the IEP Team determines that the parent will be providing transportation, the LEA must reimburse the parents in a timely manner for the costs incurred in providing transportation. See the Office of Special Education Programs’ Questions and Answers on Serving Children with Disabilities Eligible for Transportation, November 2009. The LEA may request Medicaid reimbursement if the parent personal vehicle has been specially adapted consistent with the SBS guidance.

FAQ ID:162431


Are there any Federal laws that restrict charter and/or private schools from engaging in a RMTS for the purpose of administrative and/or direct service claiming?

As stated on page 44 of the 2023 Comprehensive Guide to Medicaid Services and Administrative Claiming, if public charter schools are funded predominantly by State and local funds, including local tax revenue or appropriations, similar to other governmental entities, they may be eligible to provide the non-federal share of Medicaid or CHIP expenditures through CPEs.

However, other school entities that are not units of State or local government, including private schools, would not be considered governmental entities under 42 CF.R. § 433.51(b) and § 457.220. Direct payments to private or non-governmental educational institutions for Medicaid and CHIP SBS are available but are typically funded by State appropriations to the Medicaid/CHIP agency. Private and other non-governmental school entities may not participate directly in a CPE. However, an LEA that is a unit of government can contract with providers to provide eligible Medicaid/CHIP services to children in private entities, and CPE the contracted costs, as long as the arrangement adheres to the requirements discussed on page 43 in the 2023 Comprehensive Guide to Medicaid Services and Administrative Claiming.

In addition to a cost methodology, LEAs that are units of government may also transfer the non-federal share funds via intergovernmental transfers (IGTs) to the SMA for services provided in private schools as long as the provider receives and retains the entire Medicaid payment described in the Medicaid State plan.

FAQ ID:162341


What is a Random Moment Time Study?

Per 45 C.F.R. § 75.430(i)(5), a Random Moment Time Study (RMTS) is a type of “substitute system” used for determining and documenting time spent on, and therefore the costs of, Medicaid administrative and direct service activities. Per page 108 of the 2023 Comprehensive Guide to Medicaid Services and Administrative Claiming, a RMTS is a statistically valid sampling methodology that can be used by States and LEAs to determine how much time eligible staff spend performing Medicaid reimbursable work activities. The RMTS is used to determine a statistic that is applied to salary and fringe benefits for qualified providers and reported on a cost report for direct medical services. A RMTS is generally used in an allocation of a cost pool to allowable medical, administrative (if applicable), and unallowable moments that is further allocated to Medicaid using a Medicaid Eligibility Ratio (MER). The RMTS and supporting documents become part of the documentation for the claim. The RMTS is used to determine a statistic that is applied to salary and fringe benefits for qualified providers and to other payable costs that are reported on a cost report for direct medical services.

A RMTS must reflect all of the time and activities (whether allowable or unallowable under Medicaid) performed by school employees. The RMTS sample universe (or Participant List) should include all staff who potentially perform Medicaid direct services or administrative activities. LEAs should consider both job title and job function when determining which individual staff members should be included in which cost pool.

FAQ ID:162291


What documentation is required for claiming FFP for Medicaid SBS? Does service documentation need to include the Medicaid enrollment status of an individual practitioner (not just the LEA)?

As stated on page 91 of the 2023 Comprehensive Guide to Medicaid Services and Administrative Claiming, as required by CMS, the supporting documentation file for each claim of FFP must include, at a minimum, the following:

  • Date of service
  • Name of recipient
  • Medicaid identification number
  • Name of provider agency and person providing the service
  • Nature, extent, or units of service
  • Place of service

Within an IEP many of the above requirements may be found, including:

  • Name of recipient/child
  • Eligibility for IDEA services and the child’s present level of achievement
  • Name of provider agency/LEA
  • Nature, extent, or units of service (called the frequency and duration of services)
  • Place of service (called either the location or placement)

LEAs should review their State’s guidance for service documentation. Many States require additional information beyond the CMS requirements, such as a diagnosis code.

FAQ ID:162371


What are examples of allowable Medicaid State program administrative activities?

Medicaid and the Children’s Health Insurance Program (CHIP) can reimburse states for expenditures incurred by Local Education Agencies (LEAs)/school districts for the costs of administrative activities that support the provision of medical services covered under Medicaid or CHIP. Examples of allowable Medicaid and CHIP administrative activities can be found on page 75 of the 2023 Comprehensive Guide to Medicaid Services and Administrative Claiming. In general, some categories where administrative activities can fall include:

  • Medicaid and CHIP outreach.
  • Facilitating Medicaid and CHIP eligibility determinations.
  • Transportation-related activities in support of Medicaid and CHIP services.
    • Note, when the State claims federal financial participation (FFP) for necessary transportation as an optional medical service, the State must not also claim the same transportation expenditures as an administrative activity, which would result in duplicative reimbursement.
  • Translation and interpretation services related to covered services.
  • Program planning, policy development, and interagency coordination related to Medicaid and CHIP.
  • Medicaid- and CHIP-related training.
  • Referral, coordination, and monitoring of Medicaid and CHIP services (distinct from case management activities covered as a medical service).

FAQ ID:162306


CMS has communicated a recommendation for a 15 percent oversampling. Is this intended to become standard practice, or is it to be regarded as a suggestion?

CMS’ longstanding standard policy has been to recommend a 15 percent oversampling for RMTS to ensure a valid response rate of at least 85 percent or include all nonresponses as non-Medicaid and unallowable.

In general, all completed responses should be used in an RMTS. However, CMS allows for the use of an alternate methodology in cases where the TSIP specifies an oversample to ensure an adequate number of valid responses for the treatment of time study nonresponses are achieved. The alternate methodology CMS historically has approved uses an 85 percent valid response rate. CMS recommends an oversample of 15 percent to ensure an adequate number of valid responses are received and to meet the required precision level. Per page 113 of the 2023 Comprehensive Guide to Medicaid Services and Administrative Claiming, an oversample may be used only to compensate, not substitute, for the potential number of nonresponses.

FAQ ID:162346


Can a State bill for extended school year services or other services that occur outside of school hours or the school year? (e.g., provided after school hours or on weekends)?

Generally, yes, but how this is achieved is dependent on the reimbursement methodology the State has approved for SBS in its Medicaid State plan. If SBS in a State are paid through fee for service (FFS), then each billed service is claimed and paid as provided in the State plan, regardless of when it occurs.

If a State has a cost methodology in the State plan that uses a time study, the time study must include 100% of providers’ billable time and account for their regular schedules in the methodology and in the time study implementation plan (TSIP). In this case, the providers’ schedules should include after-school hours for programs that are intended to be captured. If these programs are contracted, the contracted costs must also be included in the cost report. If a State does not currently have these programs included in their approved SBS reimbursement methodology, the methodology may have to be amended to capture the additional services. This may include revisions to the SPA, TSIP, PACAP, or other documents, as needed.

In the case of summer activities (i.e., non-regular school days when schools are not capturing any Medicaid services), a time study should be performed to cover these periods. Anytime there are Medicaid services performed and captured in a cost methodology, that time needs to be accounted for in the CMS-approved TSIP, and the allocations explained in the SPA. This is especially true for children with Individualized Education Programs (IEPs) who are eligible for Medicaid and require special education and related services after school hours, on weekends, and/or extended school year services (defined in 34 C.F.R § 300.106). SMAs must have procedures in effect that allow for time studies to capture 100% of providers’ time delivering extended school year services. No estimations of Medicaid services can be calculated for vacation or other periods not covered in the time study.

FAQ ID:162421


Where should inquiries regarding the expansion of school-based services under Medicaid and the 2023 Comprehensive Guide to Medicaid Services and Administrative Claiming be directed?

All inquiries for the TAC and CMS regarding Medicaid School-Based Services and the 2023 Comprehensive Guide to Medicaid Services and Administrative Claiming should be directed to the TAC mailbox at SchoolBasedServices@cms.hhs.gov. More information on where to send SPA submission packages, including submission systems, pages, and CMS 179 Forms, can be found on Slide 9 of the following CMS Training Slides: https://www.medicaid.gov/state-resource-center/downloads/spa-and-1915-waiver-processing/training-slides.pdf

FAQ ID:162311


If an RMTS activity indicates the delivery of an evaluation (psychological, therapy, etc.) where medical necessity is determined through documentation, but no plan is developed, is code 4C the appropriate code?

If medical necessity has been determined, Code 4C. Direct Medical Services – Covered on a Medical Plan of Care, Not Covered as IDEA/IEP Service is the correct code. This code should be used when district staff (employees or contracted staff) provide covered direct medical services under the SBS Program where documented on a medical plan other than an IEP/IFSP or where medical necessity has been otherwise established.

FAQ ID:162396


What is the process and timeline for CMS review and approval of SPAs? Additionally, what are the essential requirements for an SPA?

In order to submit an SPA package, States will formally submit a cover letter that briefly states the intention behind the SPA, a revised Form 179, the revised, applicable State plan pages, and if applicable, a sample cost report with cost report instructions. Please note that CMS does not formally approve the cost report, however the agency’s analysis of it will help to ensure the State is determining cost in a manner consistent with applicable regulation and statutes. Once a State submits an SPA to CMS, the agency has 90 days in which it can approve the SPA, disapprove the SPA, or formally request more information to determine whether the SPA comports with applicable regulations and statutes. If the agency sends a formal request for additional information (RAI), the State then has 90 days to formally respond to the RAI. Once the State responds, CMS has 90 days to either approve or disapprove the SPA.

FAQ ID:162411

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