While schools are legally liable to provide IDEA-related health services at no cost to the eligible students Medicaid reimbursement is available for these services because section 1903 (c) of the ACT requires Medicaid to be primary to the U.S. Department of Education for payment of the health-related services provided under IDEA.
Fee-For-Service School-Based Health Services (SBHS) is a cost-sharing (Federal Financial Participation (FFP) matching) program in which the Education Agency (EA) as an enrolled public entity is responsible for paying the non-federal matching share of the amount of the claims submitted to DHS for medically necessary services provided in an education setting specified on a Medicaid-eligible child’s IEP or IFSP.
Section 1903 of the Social Security Act
Authorizes states with an approved State plan to access reimbursement for Medicaid covered School-Based Health Services (SBHS) on a Fee-For-Service basis included in a child’s IEP/IFSP.
Federal matching funds under Medicaid are available for the cost of administrative activities that directly support efforts to identify and enroll potential eligibles into Medicaid and that directly support the provision of medical services covered under the state Medicaid plan. To the extent that school employees perform administrative activities that are in support of the state Medicaid plan, federal reimbursement may be claimable through the “MAC” program.
Treatment for minor acute health conditions, such as scratches, bruises, headaches, colds, application of Band-aids or administration of non-prescriptive medications
Conditions that have no useful treatment
Treatments that are not generally effective
NOT Covered Services Integral to Direct Services
Administrative activities such as coordinating, follow-up, or monitoring performed in support of direct medical/health services that are NOT covered or reimbursable under the Medicaid FFS program are also NOT reimbursable under the Medicaid Administrative Claiming Program.
Administrative activities performed in support of direct medical/health services that are not covered or reimbursable under the Medicaid program are NOT reimbursable under the Medicaid Administrative Claiming Program.
In order for a medical/health service to be reimbursable, the provider furnishing such services must be an enrolled or participating Medicaid provider and bill Medicaid for the service.
If the provider is not an enrolled or participating Medicaid provider or chooses not to bill Medicaid for the services rendered, then the service cannot be reimbursed and the administrative expenditures related to the service are also not allowable.
An education agency does not have to be an enrolled or participating Medicaid provider in order to claim referrals of students to Medicaid-covered medical/health services provided in the community, as long as the provider rendering the services is an enrolled or participating Medicaid provider.
Referrals made for Medicaid covered health services provided by Licensed Health Care Professionals who work for actively enrolled Medicaid providers and who are billing Medicaid may be claimed under code C1. These include:
Reporting Medicaid Administrative Claiming Activities which are integral to or an extension of direct or consultative services are not claimable :
An Oregon Medical Board Licensed Health Professional cannot claim Code C1 activities, such as referrals, monitoring, gathering history or background information in advance of a referral, the coordination of Medicaid covered services, OR Code D1 activities, such as scheduling or arranging transportation to Medicaid covered services and scheduling, arranging or providing translation for Medicaid covered services which are integral or related to consultation or direct treatment services provided for a child by that individual .
Delegated Health Care Assistant (trained by an RN to perform delegated Nursing tasks)
Activities that meet the descriptions of Code C1 and D1 (ie: coordination, referral, gathering history in advance of a referral, scheduling, arranging, or providing translation services necessary to understand treatment of a health condition or scheduling or arranging of transportation services to a Medicaid covered service), which are integral or related to consultation, care coordination, or direct treatment services provided for a child by the Direct Service Provider are considered direct services and must be coded F. This is true regardless of whether or not the education agency the direct service provider works for is an active participating Medicaid Provider.
Clear and concise supporting documentation must be maintained by all direct service providers who report Code C1 or D1.
Direct Service Providers may claim B1 and E1 activities without this same concern.
the school is enrolled with the Division of Medical Assistance programs as a School Medical (SM) Medicaid provider and actively billing SBHS specified on a child’s IEP or IFSP for reimbursement under the Fee-For-Service program (NOTE: If the referral is provided by an ESD employee who works in the district and the ESD is an active participating Medicaid provider, then the referral may be claimed under code C1.1); and
the referral is made to a staff member who holds a license from an Oregon Medical Licensing board
Referrals made to staff licensed/credentialed through TSPC (only) for the purpose of a health evaluation, diagnostic testing, and behavior counseling services are not claimable under code C1 (i.e., school psychologist, school counselor, teacher with a speech endorsement).
Referrals for state-mandated health services are NOT claimable.
For example, state laws may require that immunizations be provided to all school children, regardless of the child’s income status or whether the child is Medicaid eligible. In such a case the administrative activities related to assisting the child to obtain such immunizations in the school would not be reimbursable as a Medicaid administrative cost.
Notifying parents regarding immunizations during exclusions as required by education would not be a claimable activity under MAC.)
Referrals to NON-Medicaid health care providers, such as:
School Districts and ESD’s which are not enrolled as a Medicaid provider or not actively participating in Medicaid billing and;
Private health plans and a division of Kaiser Permanente (some Kaiser Permanente health plans are covered by Medicaid)
TSPC “ ONLY” Licensed School Counselors (NOTE: If in doubt, always be conservative in recording claimable activities. Instead code them A or F.)
Knowledge, Skills and Abilities for Initial School Counselor
A TSPC Licensed School Counselor may provide the following within the scope of their license:
1(b) Develop, design, implement, monitor, and evaluate a comprehensive developmental and inclusive school counseling program that integrates Oregon's four developmental domains: academic (learn to learn), personal/social (learn to live), career (learn to work), and community involvement (learn to contribute)
According to Oregon Administrative Rules a TSPC Licensed School Counselor does not provide direct “health” services to students such as, diagnostic evaluations, health assessment and behavior counseling for an identified health condition. Therefore, referrals and coordination activities made to Medicaid providers for Medicaid covered services by a TSPC Licensed School Counselor are claimable activities, as they are not providing direct health or medical services.
If a referral is made to a TSPC Licensed School Counselor for a diagnostic health evaluation, the referral is not claimable as Medicaid does not recognize TSPC licensure as meeting the criteria for Medically Qualified Staff who may bill Medicaid for Medicaid covered services.
Knowledge, Skills and Abilities for Initial School Psychologist License
A TSPC Licensed School Psychologist may provide the following within the scope of their license:
2a) Candidates demonstrate skill in assessing or providing for assessments in the following areas: academic knowledge and achievement, intelligence and cognitive functioning, scholastic aptitude, personality, emotional status, social skills and adjustment, adaptive behavior, language and communication skills, sensory and neurological functioning, educational setting, and family/environmental influences.
(3) Consultation and Collaboration: Candidates have knowledge of behavioral, mental health, collaborative, and/or other consultation models and methods and of their application to particular situations.
(8) Prevention, Crisis Intervention, and Mental Health: Candidates have knowledge of human development and psychopathology and of associated biological, cultural, and social influences on human behavior. Candidates provide or contribute to prevention and intervention programs that promote the mental health and physical well-being of students. Candidates have knowledge of crisis intervention and collaborate with school personnel, parents, and the community in the aftermath of crises.
According to Oregon Administrative Rules a TSPC Licensed School Psychologist may provide direct “health” services to students such as, diagnostic evaluations and assessment and behavior counseling for an identified health condition. Referrals and coordination of Medicaid covered services made by a TSPC Licensed School Psychologist to Medicaid providers for a child in which they provide direct “health” services are considered integral to or an extension of a direct service and must be coded F.
If a referral is made to a TSPC Licensed School Psychologist for a diagnostic health evaluation, the referral is not claimable as Medicaid does not recognize TSPC licensure as meeting the criteria for Medically Qualified Staff who may bill Medicaid for Medicaid covered services.
An easy way to keep code C1 & E1 straight when recording MAC activities is to remember the following:
C1 = Child specific
E1 = Everyone Benefits
Medicaid Administrative activities that may be reported under code C1 involve work specific to a child and/or their families.
Whereas, Medicaid Administrative activities that may be reported under code E1 involve actions that benefit an entire population of children.
C1 - Referral, Coordination, Monitoring Note: C = Child
Referring students for medical, mental health, dental health and substance abuse evaluations and services covered by Medicaid/OHP (includes gathering information in advance of referrals).
Referrals made to staff licensed/credentialed through TSPC only for the purpose of a health evaluation, diagnostic testing, and behavior counseling services are not claimable under MAC code C1 (i.e., school psychologist, school counselor, teacher with a speech endorsement). Such activities are not reimbursable by Medicaid, yet are still considered a direct service and must be coded F.
The free care provision serves to limit the ability of schools to bill Medicaid for covered services provided to Medicaid-eligible children because schools that provide needed health services often provide them to all students free of charge. For example, state laws may require that immunizations be provided to all school children.
In such a case, administrative activities related to assisting a child to obtain such immunizations “ in the school” would NOT be reimbursable as a Medicaid administrative cost (see pg. 21 CMS MAC 2003 guide). For example:
Activities performed in association with a free immunization clinic offered in the school
Administrative activities performed in association with the immunization exclusion requirements, such as:
Performing a primary review summary
Mailing exclusion orders
Completing a county immunization status report
See the following web-link regarding Oregon school immunization requirements in the Oregon Immunization Law Handbook: http://www.oregon.gov/DHS/ph/imm/school/
However, making referrals for and/or scheduling appropriate immunizations outside the school setting and that are Not Free of charge and are billed to Medicaid , whether during exclusion or not are claimable under MAC code C1.1. (NOT to include the non-claimable examples noted in the previous slide or as identified in the Oregon Immunization Law Handbook.
Examples of claimable referrals for immunizations include:
Referrals made for school-age children and/or their families outside the school setting that are not free of charge (ie: referral for immunizations to a an enrolled Medicaid provider.)
The 2003 CMS Medicaid Administrative Claiming guide indicates the following are covered under code C1:
Providing follow-up contact to ensure that a child has received the prescribed medical/dental/mental health services covered by Medicaid.
Monitoring and evaluating the Medicaid service components of the IEP as appropriate .
When necessary and appropriate claimable scenarios may include:
A classroom teacher who works closely with a student receiving Medicaid-covered services on an IEP is involved in a scheduled meeting necessary to monitor and evaluate the medical service components of the IEP (this excludes the actual IEP meetings).
A classroom teacher who works closely with a student makes follow-up contact with a qualified Medicaid Health Services provider to ensure services previously prescribed or referred for were received.
Scheduling and arranging transportation to OHP covered services.
Arranging for or scheduling transportation services to a Medicaid covered service or treatment.
Does NOT include the provision of the actual transportation service or the direct costs of the transportation (bus fare, taxi fare, etc, but rather the administrative activities (related paperwork, clerical activities, staff travel time, etc.) involved in providing the transportation. ( See page 21 of CMS May 2003 Guide School Based Medicaid Administrative Claiming)
Scheduling, arranging or providing translation for OHP covered services.
Arranging for or providing translation services (oral and signing) that assist the individual to access and understand necessary care or treatment covered by Medicaid.
Developing translation materials that assist individuals to access and understand necessary care or treatment covered by Medicaid.
E1 – Program Planning, Policy Development & Interagency Coordination Note: E = Everyone
Developing strategies and policies to assess or increase the capacity of school medical/dental/mental health programs (includes workgroups)
Identifying gaps or duplication of medical/dental/mental services and developing strategies to improve the delivery and coordination of these services.
Developing procedures for tracking families’ requests for assistance with medical/dental/mental health services and providers, including Medicaid.
This does not include the actual tracking of requests for Medicaid services.
Developing Medicaid provider list to assist staff in referring families to Medicaid providers.
E1 – Program Planning, Policy Development & Interagency Coordination
Working with other agencies and/or providers to improve the coordination and collaboration and delivery of medical, mental health and substance abuse services.
Working with other agencies to evaluate the need for medical/dental/mental services in relation to specific populations or geographic areas.
Working with other agencies and/or providers to improve collaboration around the early identification of medical/dental/mental problems.
Monitoring the medical/mental health/dental health delivery system in schools. For example:
Developing advisory or work groups of health professionals to provide consultation, advice and monitoring of the delivery of health care services to the school populations.
Evaluating the need and/or effectiveness of medical services provided in the school setting (such as a school based health center)
Providing Direct Services vs. Administrative Activities
The Centers for Medicare & Medicaid Services (CMS) rule states: Activities that are considered integral to, or an extension of direct medical services, are NOT CLAIMABLE as an Administrative expense (e.g., patient follow-up, patient assessment, patient counseling, patient education, patient consultation, billing activities). These activities must be reported under Code F, Direct Medical Services. (See page 27 of the CMS 2003 Medicaid School-Based Administrative Claiming guide.)
Section V(A) of the 2003 CMS Medicaid Administrative Claiming Guide states (pg 37):
Documentation maintained in support of administrative claims must be sufficiently detailed to permit CMS to determine whether the activities are necessary for the proper and efficient administration of the state plan. Simply checking a box on a time study form does not facilitate independent validation of the sample results. … It is critically important for additional documentation to be maintained, in order to verify the appropriateness of the claims in terms of allowability and allocability and to limit the risk of the federal government.
For survey claims where 10% or more of the total time reported is claimable under MAC, supporting documentation is required. Supporting documentation must:
Be clear and concise
Use actions verbs as identified under each claimable code in the MAC coding guide (ie: referred, gathered information, coordinated, arranged, scheduled, etc) to accurately describe claimable activities reported in the MAC survey.
Supporting documentation must be maintained for a period of seven years.
Children are one third of our population and all of our future…