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Updating Your State's School-Based Medicaid Plan: Key Elements of Effective Implementation

Jun 14, 2023

Student health is a crucial factor in academic success, and state school-based Medicaid programs play a critical role in providing students with access to the health services they need while in the school environment. With recent updates and forthcoming guidance from CMS, states have a chance to identify existing services that may now qualify for reimbursement and expand the range of services available to students—contributing to improved health and educational outcomes. 

Effective implementation is vital to amplifying the impact of updates to your state's school-based Medicaid plan. This article will explore the latest opportunities to expand eligible services and the key elements that can help your state effectively implement these changes. 

Updating the state school-based Medicaid program 

In most cases, states will need to amend their school-based Medicaid state plan in order to take advantage of recently expanded coverage for student Medicaid recipients. This process involves several important steps, including: 

Implementation is a key component for achieving improved outcomes. 

  • Cultivating buy-in among stakeholders in various agencies and functions.  
  • Determining a baseline measure of knowledge about current Medicaid claiming. 
  • Developing a manual for your state’s current school-based Medicaid claiming program. 
  • Navigating questions and requested changes from CMS. 
  • Planning for implementation and training. 

Amending the school-based Medicaid plan can be a difficult and time-consuming process—sometimes taking more than a year to reach approval. However, recent changes and the expansion of eligible health services create significant opportunities for states, school districts, and students. There has never been a better time to embark upon this process, and implementation is a key component for achieving improved outcomes. 

When should you start planning for implementation? 

Rather than being the last step in the process, a smooth implementation plan begins with the decision to update and continues after CMS approves your state’s school-based Medicaid program. Starting implementation as early as possible allows for capturing necessary data and preparation for expanded reimbursement. By carefully planning for implementation from the outset, states can develop a new plan that contributes to a meaningful impact on students' health and well-being. 

It’s essential that stakeholders are invested in the implementation process. Effectively implementing a new school-based Medicaid program requires a comprehensive approach involving stakeholder engagement, training, and ongoing evaluation.  

Soliciting input from all relevant parties throughout the process can help develop buy-in and support for the plan. Conversations about professional training and how to evaluate processes and outcomes should coincide with initial discussions about what changes to make. With strong communication and buy-in among providers and other stakeholders, the entire team can focus on implementing all necessary changes to claiming and reporting. 

If you’re converting from fee-for-service to a cost-based model: 

Since implementation begins before the state plan is even finalized with CMS, this step must start especially early if your state is one of the many that will change from fee-for-service to a cost-based model. The cost-based model is more complex and requires capturing four quarterly time studies within the cost report year prior to claiming for those costs. 

It's worth noting that approved changes are effective from the submission date rather than the approval date for your updated plan. Therefore, it is crucial to capture data beginning with the plan submission date so that you can submit claims dating back to the original date of state plan submission.

Communicating the expansion 

Providers in school districts, such as superintendents and special education directors, are important stakeholders in any school-based Medicaid program and should be kept informed throughout the process. They need clear information about what is happening and how the changes could impact their teams.  

These local providers must understand how a smooth implementation and accurate reporting contribute to their districts receiving the necessary support to provide all allowable services. An outsourced partner with experience in this type of project can serve as an important resource by developing a customized communication plan that keeps your state’s key stakeholders informed and engaged. 

Professional training 

Make sure providers understand what is required of them within the updated school-based Medicaid plan and why. Business managers and health service providers will need training and detailed information about specific reporting requirements for the revised plan, especially if the state moves to a cost-based model. While increased reporting requirements may burden service providers, the data helps prove the need for staffing requests, new programs, and other necessary components of providing essential health services to students. 

Ongoing assessment and adaptation 

Learning never stops. As with any major program, planning for ongoing monitoring and evaluation of processes is important. This could include desk reviews, time studies, cost report audits, etc. Tracking data will help you determine key outcomes of the program:  

  • How much time is spent providing services?   
  • Are services reaching more students?   
  • Are providers/school districts delivering more services?   
  • How can this be tracked and improved?  

Discuss these issues directly with key stakeholders and providers.

Be aware of the paperwork burdens placed on local education agencies. It's important to discuss these issues directly with key stakeholders and providers in order to understand where bottlenecks exist and research ways to increase efficiency.  

Finally, it's essential to review and update the manual regularly. This document is an important tool to guide day-to-day processes and consistent decision-making about your school-based Medicaid program. It should also answer common questions that providers will have about claimable services versus non-claimable services, valid service types, and how your state interprets existing CMS guidance. Keeping this important asset up to date will support the main goal of providing as many allowable health services as possible to students so that both health and education outcomes can improve. 

Support for implementing your state’s updated school-based Medicaid plan 

Updating your state school-based Medicaid plan can be a challenging and complex process involving coordination across many agencies and decision-makers. However, by prioritizing implementation and engaging with stakeholders throughout the process, states can develop a new plan that supports a measurable impact on the health and well-being of students.  

Many states lack the experience and staffing required to execute all the components of implementation. A knowledgeable outsourced partner can provide valuable expertise in planning necessary communications, training, and updates. They can also connect you with other states to share new ideas for addressing similar problems.  

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A Guide to Updating Your State's School-based Medicaid Program

Updating your state school-based Medicaid plan can be a challenging and complex process involving coordination across many agencies and decision-makers.

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Jason Coker

Jason Coker is an Associate Director in the firm’s Assurance group and has over 15 years of experience. 

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