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
For direct services that may be covered and paid for by Medicaid and CHIP, the provider furnishing such services must be enrolled in the State Medicaid or CHIP program, as applicable (see page 26 of the Comprehensive Guide). Providers who are not eligible for or enrolled in Medicaid should generally not be included in the Direct Services cost pool.
However, a non-Medicaid provider can conduct and claim Medicaid administrative activities. These providers may be included in the Administrative Activities cost pool, with only the time spent performing Medicaid-allowable administrative activities counted towards the allocable costs. In a time study, the providers should code any Medicaid administrative activities completed during their assigned moment so that they are included in the allocation ratio. A description of calculating cost pools is available on pages 87 and 88 of the Comprehensive Guide.
Examples of reimbursable school-based prevention services were provided during our November 14 webinar, Expanding Preventive Behavioral Health Services in Schools. The slides and recording from this webinar are available on the Medicaid SBS Events page. General examples can be found on slides 15-16, and examples from specific states can be found on slides 20-23.
The requirement to perform a time study during vacation periods depends on the circumstances the LEA or the claiming unit faces. Each time study is independent, and the sample universe is determined before it is conducted; therefore, only employees performing Medicaid-related activities would be included in the sample universe for that time study period. The Random Moment Time Study (RMTS) must include LEAs that seek to bill and/or be paid for services. If the LEA does not want to participate in providing services, it will not be included in the sample universe.
Any LEA that bills for Medicaid services during any vacation period must be included in the RMTS for the period in question to ensure that all services allocable to Medicaid are captured. However, suppose an LEA will not bill for any services during the vacation period in question and does not include any vacation period expenditures in the cost report. In that case, they may be excluded from the study sample for that period. (For more information, see page 114 of the Comprehensive Guide)
There is no prohibition on claiming for administrative activities if the LEA does not also provide direct services. LEAs may choose to participate in only administrative activities, only direct services, or both administrative and direct services.
An LEA can claim the full scope of administrative activities without providing proof of a paid service. Please see Example 3 on page 27 of the Comprehensive Guide:
- Example 3. The school is not a participating provider. The school program refers Medicaid-eligible children to participating Medicaid providers in the community. If the school performs administrative activities related to the services billed to Medicaid by community providers, the costs of such activities are allowable under the Medicaid program. Such activities would be reported under the appropriate Medicaid-related activity code.
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).
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.
Yes, States are expected to apply the 2023 Comprehensive Guide to Medicaid Services and Administrative Claiming guidance to all MAC programs for all entities. Both previous guidance documents issued by CMS, including the 1997 School-based Services Technical Review Guide and the 2003 School-based Administrative Claiming Guide, are superseded by the 2023 Comprehensive Guide to Medicaid Services and Administrative Claiming.