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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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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

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What are the objectives of the TAC, and how can stakeholders best engage with and contact the TAC? Furthermore, what types of support can stakeholders expect to receive from the TAC?

Generally, the TAC goals are to:

  • Support SMAs, SEAs, LEAs, and school-based entities seeking to expand their capacity for providing Medicaid SBS.
  • Help states reduce administrative burden and simplify billing for, LEAs, in particular small and rural LEAs, and support compliance with Federal requirements regarding billing, payment, and recordkeeping, including by aligning direct service billing and school-based administrative claiming payment systems.
  • Support state entities in obtaining reimbursement for providing and expanding Medicaid SBS, including a comprehensive list of best practices and examples of approved methods that SMAs and LEAs have used to pay for, and increase the availability of, assistance under Medicaid, including expanding State programs to include all Medicaid-enrolled students, providing EPSDT services in schools, utilizing telehealth, coordinating with community-based mental health and substance use disorder treatment providers and organizations, coordinating with managed care entities, and supporting the provision of culturally competent and trauma-informed care in school settings
  • Ensure ongoing coordination and collaboration between states, ED, and CMS regarding Medicaid SBS.
  • Provide guidance with regard to utilization of various funding sources.

Please email the TAC at SchoolBasedServices@cms.hhs.gov for any questions about Medicaid SBS or technical assistance.

FAQ ID:162331

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I'd like to join the TAC webinars. Where can I sign up, and will there be a recording if I can't make it to the live session?

The TAC’s upcoming events with registration information can be found here: Upcoming Events | Medicaid. Registration links will also be provided via email. Individuals from SMAs, SEAs, LEAs or school-based entities are invited to email the TAC at SchoolBasedServices@cms.hhs.gov to be added to the distribution list. For those unable to attend, recordings of webinars will be posted two weeks after the event here: Past Events | Medicaid. Those registered for the webinar will be sent the recording when it becomes available.

FAQ ID:162286

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Given that the expansion of school-based services is still new for many States, how can the TAC and CMS help States better understand EPSDT services?

The TAC is working to compile best practices from States and work with SEAs, LEAs, and SMAs to come up with ways to expand school-based services. EPSDT is a guarantee of coverage for certain benefits for EPSDT-eligible beneficiaries, but not an independent Medicaid service. The TAC plans to cover the subject of EPSDT during webinar in 2024. Additional information on the EPSDT benefit can be found here: Early and Periodic Screening, Diagnostic, and Treatment

FAQ ID:162296

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How does the TAC plan to directly interact with LEAs, and what methods will be employed to collaborate with SMAs and LEAs to enhance their effectiveness?

The TAC is actively collaborating with SMAs, advocates, and LEAs to gather insight and opinions on various topics, with the aim of formulating best practices for SBS policies. Through a series of webinars and virtual meetings, the TAC will explore and address a diverse range of subjects to inform best practices in Medicaid SBS and service implementation. Additionally, the TAC is in the process of creating resource materials to aid LEAs and SEAs in effectively managing SBS programs.

FAQ ID:162301

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Where can I find an application to apply for the Medicare Savings Program (MSP)?

The Medicare Savings Program (MSP) Model application can be found here: Medicare Savings Programs (MSP) Model Application for Medicare Premium Assistance

FAQ ID:95161

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Please clarify that state flexibility to reimburse in the aggregate extends to reimbursement rates for I/T/U pharmacies and FSS drugs, and that states can establish rates that are based on a variety of data sources, which may include FSS prices, national and State price surveys, AMP data, and other price benchmarks.

The new AAC requirements were designed to more accurately reflect the pharmacy providers' actual prices paid to acquire drugs and the professional services required to fill a prescription. We agree that each state is able to establish rates that satisfy (or are consistent with) AAC and may be based on a variety of data sources, which may include FSS prices, and other pricing benchmarks.

FAQ ID:95111

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If a state can prove that they are under the aggregate limits of AAC and PDF and have strong participation by pharmacies, are they required to adopt the AAC and PDF reimbursement methodology at the individual claim level?

All states are required to adopt the AAC and professional dispensing fee methodology; however, it is not required to be adopted at the individual claim level, but in the aggregate. In accordance with the regulatory requirements at 42 CFR 447.512(b), the state is responsible for establishing a payment methodology, that must not exceed, in the aggregate, payment levels that the agency has determined by applying the lower of the AAC plus a professional dispensing fee or the providers' usual and customary charges to the general public. In conjunction with this the state is also responsible to ensure that pharmacy reimbursement is consistent

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with the requirements of section 1902(a)(30)(A) of the Act, which specify that provider reimbursement rates should be consistent with efficiency, economy, and quality of care while assuring sufficient beneficiary access.

FAQ ID:94691

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If a state is already using actual acquisition cost (AAC) as their reimbursement methodology, does the state need to file a State Plan Amendment (SPA) or provide assurances that the current formula meets requirements established in the final rule? Is there a requirement for such states to file a SPA to provide assurance that the state's current dispensing fee amount meets the requirements of the final rule?

If a state is already making payment for prescription drugs under its state plan based on AAC, it may continue to use that methodology. However, if a state decides to change its AAC model of reimbursement, (e.g., the state decides to use the National Average Drug Acquisition Cost (NADAC) instead of a state survey to implement a payment methodology based on AAC), the state must submit a new SPA through the formal SPA process for review.

Additionally, the state should review its currently approved professional dispensing fee (PDF) to determine if, in light of the regulation (42 CFR 447.518), the PDF needs to be revised and a SPA needs to be submitted. The state does not have to submit a new SPA to provide assurance that its dispensing fee is reasonable.

Furthermore, we expect that all states, even those currently operating under an AAC reimbursement methodology, will evaluate their current state plans to determine if a SPA will be required to comply with the reimbursement requirements (including, but not limited to, AAC, PDF, 340B and the federal upper limits (FULs)).

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FAQ ID:94671

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Will there be an annual review of PDFs that are required as part of SPA approvals?

No, CMS will not perform an annual review of PDFs; however, states must consider both the ingredient cost reimbursement and the PDF reimbursement when proposing changes to ensure that total reimbursement to the pharmacy provider is calculated in accordance with requirements of section 1902(a)(30)(A) of the Act.

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FAQ ID:94676

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