Many states codified the pre-2014 restrictive school Medicaid policy on reimbursement into their state Medicaid plan. In order to leverage the current policy, which allows reimbursement for covered health services delivered to all students enrolled in Medicaid, those states need to submit a state plan amendment (SPA).
A small number of states codified the policy in state law as well. While state law can present a barrier to the implementation of the revised CMS policy, it can also serve as an important tool for catalyzing action. In those cases, state policy and program decisions would determine the opportunity for school districts to begin billing for additional populations.
State Plan Amendments
Every state has its own process for moving a SPA forward, but it’s worth noting that state Medicaid departments change state plans regularly — and Medicaid officials can advise on the formal process for pursuing a SPA.
In general, a state submits paperwork to CMS requesting the policy change and then works with CMS to iron out the details, with other stakeholders joining in as needed. While there are time clocks on how quickly the SPA process should move, CMS can start and stop the clock.
There is now a significant amount of activity around school-based Medicaid. Many states are considering expanding the program to include billing for all Medicaid-enrolled students — and to add additional services and provider-types to the list of covered benefits and services. A number of states have expressed interest in expanding their programs to increase access to behavioral health services to address unmet mental health needs.