Frequently Asked Questions

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

Yes, examples of approved SPAs for States that expanded services beyond IDEA services (e.g., Arizona, Colorado, Illinois, New Mexico) can be found on CMS' website at the following link: https://www.medicaid.gov/resources-for-states/medicaid-state-technical-assistance/medicaid-and-school-based-services/technical-assistance-materials/index.html

It's important to note that each State, District of Columbia, and territory is unique, and it is crucial to ensure that the SPA aligns with the specific needs and laws of the State.

FAQ ID:162416

The new flexibilities for SBS are policy options available to States, but are not required. If States have questions, we encourage them to reach out to the SBS email SchoolBasedServices@cms.hhs.gov to engage in any needed technical assistance.

FAQ ID:162471

States should review the 2023 Comprehensive Guide to Medicaid Services and Administrative Claiming to ensure that their current SBS policies are consistent with all federal requirements. States are required to submit any necessary changes to their SPAs, TSIP, MAC Plan, PACAP, etc., to adhere to all applicable federal requirements as discussed in the 2023 Comprehensive Guide as quickly as possible, if changes are needed, with the expectation that any necessary changes will be requested and approved by July 1, 2026. CMS encourages states to start the submission process as soon as possible to allow for optimal time for review and necessary revisions.  If the State has questions about compliance, CMS is available to assist. We encourage them to reach out to the SBS email SchoolBasedServices@cms.hhs.gov to engage in any needed technical assistance.

FAQ ID:162476