The US Department of Education (ED), has been an important partner in developing school-based guidance with the Medicaid Program. This continued collaboration seeks to build upon the comprehensive guidance and provide further materials and resources to States and Local Education Agencies (LEAs) in accomplishing the goal of increasing the number of IDEA and other Medicaid-eligible services in the school-based setting.
Guarantee of Services under IDEA:
Regulations at 34 C.F.R. Section 300.154(b)(1)-(2) discuss the “Obligation of noneducational public agencies” (including managed care entities)- clarifies that Medicaid services provided in school under IDEA for ensuring Free Appropriate Public Education (FAPE), “…may not disqualify an eligible service for Medicaid reimbursement because that service is provided in a school context.”
Resources:
Joint Guidance on the Application of FERPA and HIPAA to Student Health Records
IDEA and FERPA Crosswalk - A side-by-side comparison of the privacy provisions under Parts B and C of the IDEA and FERPA.
Technical Assistance Materials
To support State Medicaid agencies, LEAs, and school-based entities in providing and improving the delivery of covered Medicaid and Children’s Health Insurance Program (CHIP) services to enrolled students in school-based settings, CMS is providing links to sample State Plan Amendments, Time Study Implementation Plans, Administrative Claiming Plans, and Cost-Reports.
These are good examples of what a handful of States have done in implementing their school-based services programs. Some of these examples are older and may not be in full compliance with the latest CMS guidance from the 2023 Delivering Services in School-Based Settings: A Comprehensive Guide to Medicaid Services and Administrative Claiming.
Early Periodic Screening, Diagnostic and Treatment (EPSDT)
The Early and Periodic Screening, Diagnostic and Treatment (EPSDT) benefit provides comprehensive and preventive health care services for children under age 21 who are enrolled in Medicaid. EPSDT is key to ensuring that children and adolescents receive appropriate preventive, dental, mental health, and developmental, and specialty services- including in schools.
Learn more about EPSDT services and guidelines here.
Read an important informational bulletin concerning EPSDT here.
State Plan Amendments (SPAs)
SBS SPAs using a cost methodology and opened “Free Care” services:
- Arizona SPA 21-0006. Approved October 25, 2021