Massachusetts: State Plan Amendment Paves the Way for Medicaid in Schools
Earlier this year, Centers on Medicare and Medicaid (CMS) gave Massachusetts the green light to amend their Medicaid state plan, opening the door for schools to bill Medicaid health services provided to all their Medicaid-enrolled students, not just those receiving health services as part of their Individualized Education Plan (IEP) or special education plan. As we’ve highlighted in past blogs and toolkits, the free care policy limited schools seeking reimbursement for Medicaid services to services related to the IEP and other limited situations. CMS issued guidance in 2014 reversing the free care policy.
In an effort to align policy and practice with this new opportunity, Massachusetts submitted a State Plan Amendment (SPA) to revise its state Medicaid plan. This past summer CMS approved the SPA effective July 2016. The Massachusetts Executive Office of Health and Human Services (EOHHS) has yet to issue guidance on how schools should alter their billing practices. Without that guidance, it is difficult for schools to take next steps modifying their billing practices and creating opportunity for students to access a more robust set of health services inside school walls.
Even as we await guidance from the EOHHS, reviewing the state plan changes is instructive. The new state plan makes some substantive changes; the Massachusetts’ approach may inform other states’ decision-making in pursuing the free care policy reversal. First, the Massachusetts’ SPA adds some additional services and providers to its list of school-based covered services and providers. These include but are not limited to respiratory services, nutritional services, physician services, optometry services, fluoride varnish services, injury assessment and individual assessment. Second, the SPA adds an additional calculation to its cost methodology: it does not replace the existing approach but rather adds another track for calculating reimbursement for Medicaid-enrolled students not on IEPs. This is important for some states that have varying Medicaid compositions across their schools. In collaboration with our partners at Healthy Schools Campaign and National Health Law Program, we put together a short analysis of the SPA.
Advocates working on these issues will be encouraged by the expanded covered services section. The change in services is particularly relevant and important in the context of the school nurse. We know that the scope of the school nurse has expanded dramatically over the past decade to include duties that range from chronic care management of diabetes and asthma to substance use screening and referral for youth struggling with addiction and mental health issues. Finally, the addition of optometry and fluoride varnish services addresses an important community need and offers promise of not just addressing health but also chronic absenteeism and other barriers to educational success. We are excited to see the covered services more closely reflect the needs of the whole child that is focused on their future wellness and long-term opportunity.
As advocates contemplate school health as a policy priority, the Massachusetts SPA and related advocacy work can be a useful tool in advancing your work. Take a look!