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
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.
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
The following measures assess institutional rebalancing and utilization:
- LTSS Admission to an Institution from the Community
- LTSS Minimizing Institutional Length of Stay
- LTSS Successful Transition after Long-Term Institutional Stay