Frequently Asked Questions

The TAC welcomes all inquiries related to Medicaid School-Based Services in our mailbox at SchoolBasedServices@cms.hhs.gov. We will provide all the technical assistance we can and will advise contacting the State Medicaid or Education agency if further guidance is needed due to State-specific regulations.

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.

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.

The formula for State FMAP is established in statute and there is currently no FMAP specific to SBS. The FMAP for direct medical services provided in schools is the same as applicable for Medicaid or CHIP services provided in other service settings. Expenditures for Medicaid administrative activities are generally available at a 50% matching rate, with higher rates for certain activities as specified in the Social Security Act (the Act). Expenditures for CHIP administrative activities, including health services initiatives (HSIs) are available at the Title XXI enhanced or eFMAP and subject to a 10% limit on administrative expenditures.  

A Notice of Funding Opportunity (NOFO) was published in the Federal Register at https://www.govinfo.gov/app/collection/FR/ on January 24, 2024. Applications for grant funding were due March 25, 2024. Please contact the MedicaidSBSPlanningGrants@cms.hhs.gov mailbox for more information.

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.

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.

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.