Frequently Asked Questions

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.

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.

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

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.

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).

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

No, while an RMTS is typically used to identify and allocate cost, it is not the only option. States also have the flexibility to utilize an alternative methodology for reimbursement and/or allocation, provided there is appropriate documentation for CMS review of the chosen methodology. Regulations on personnel expenses in 45 C.F.R. § 75.430(i) require that charges to federal awards must be based on records that reflect the actual work performed. The records must:

• be supported by a system of internal controls that provides reasonable assurance charges are accurate, allowable, and properly allocated,
• reflect the total activity for which the employee is compensated,
• encompass both federally assisted and all other activities for which the employee is compensated, and
• support the distribution of the employee's salary or wages among specific activities or cost objectives.

First, the activities must be allowable as State program administrative activities. Secondly, the State and/or claiming unit must implement a methodology to properly identify and allocate Medicaid’s portion of cost associated with the allowable State program administrative activity. Finally, the identification and allocation of this cost must be documented in the State’s Public Assistance Cost Allocation Plan (PACAP). According to 45 C.F.R. § 95.517, State Medicaid agencies (SMAs) that intend to claim for allowable administrative activities must have an approved PACAP. As the PACAP is primarily used by the Federal cognizant agency to allocate cost incurred by one direct federal awardee, yet funded by another federal awardee, there may be instances where costs applicable to allowable State program activities are incurred and funded by the SMA. In this instance, the State may identify and allocate the cost via a Medicaid Administrative Claiming (MAC) Plan and include a reference to the identification and allocation of the cost via the MAC Plan in its PACAP.

CMS encourages SMAs to reimburse school districts their allowable costs of conducting Medicaid and CHIP administrative activities. School districts should work with SMAs to develop a plan to document their costs so that the SMA can distribute Medicaid and CHIP FFP to school districts in proportion to each district’s relative expenditures for Medicaid and CHIP administrative activities.

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.