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.
Frequently Asked Questions
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
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.
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.
Information on the NCCI program in Medicaid can be found on the NCCI Medicaid webpages which includes an NCCI for Medicaid FAQ Library.
No, a state is not required to reference or rely on the ASAM Criteria however, states should use guidelines/patient placement tools that are comparable to ASAM criteria. The State Medicaid Director Letter describing the SUD section 1115 demonstration opportunity references the ASAM Criteria as a recognized standard and an example of a patient placement assessment tool that states could use. Participating states are expected to ensure that providers use an SUD-specific, multi-dimensional assessment tool in determining the types of treatments and level of care a beneficiary with an SUD may need. The ASAM Criteria is referenced as a representative example of such an assessment tool.
Some states proposed alternative needs assessment tools. CMS reviews each alternative proposal on an individual basis, and CMS has so far determined that those alternatives are comparable to the ASAM Criteria and meet the expectations for this demonstration initiative. In addition, participating states are expected to implement provider qualifications for residential treatment providers that reflect well-established standards for these treatment settings. Again, the ASAM Criteria is referenced as an example of a resource that states may use for determining those standards.
The Medicare Savings Program (MSP) Model application can be found here: Medicare Savings Programs (MSP) Model Application for Medicare Premium Assistance
No. Although a comprehensive assessment may include falls risk assessment elements, this measure does not require the risk assessment elements to be documented as part of a comprehensive assessment. For this measure, a falls risk assessment is considered complete if the member record includes any documentation of a balance/gait assessment, and documentation of assessment of postural blood pressure, vision, home fall hazards, and/or medications.
Date: March 1, 2019
Topics:
Managed Long Term Services and Supports (MLTSS)
Screening, Risk Assessment, and Plan of Care to Prevent Future Falls
Subtopics:
Falls Part 2 (Risk Assessment and Plan of Care)
Screening, Risk Assessment, and Plan of Care to Prevent Future Falls: Falls Part 2 (Risk Assessment and Plan of Care)