Frequently Asked Questions

Medicaid and the Children’s Health Insurance Program (CHIP) can reimburse states for expenditures incurred by Local Education Agencies (LEAs)/school districts for the costs of administrative activities that support the provision of medical services covered under Medicaid or CHIP. Examples of allowable Medicaid and CHIP administrative activities can be found on page 75 of the 2023 Comprehensive Guide to Medicaid Services and Administrative Claiming. In general, some categories where administrative activities can fall include:

• Medicaid and CHIP outreach.
• Facilitating Medicaid and CHIP eligibility determinations.
• Transportation-related activities in support of Medicaid and CHIP services.
  • Note, when the State claims federal financial participation (FFP) for necessary transportation as an optional medical service, the State must not also claim the same transportation expenditures as an administrative activity, which would result in duplicative reimbursement.
• Translation and interpretation services related to covered services.
• Program planning, policy development, and interagency coordination related to Medicaid and CHIP.
• Medicaid- and CHIP-related training.
• Referral, coordination, and monitoring of Medicaid and CHIP services (distinct from case management activities covered as a medical service).

FAQ ID:162306

In order to submit an SPA package, States will formally submit a cover letter that briefly states the intention behind the SPA, a revised Form 179, the revised, applicable State plan pages, and if applicable, a sample cost report with cost report instructions. Please note that CMS does not formally approve the cost report, however the agency’s analysis of it will help to ensure the State is determining cost in a manner consistent with applicable regulation and statutes. Once a State submits an SPA to CMS, the agency has 90 days in which it can approve the SPA, disapprove the SPA, or formally request more information to determine whether the SPA comports with applicable regulations and statutes. If the agency sends a formal request for additional information (RAI), the State then has 90 days to formally respond to the RAI. Once the State responds, CMS has 90 days to either approve or disapprove the SPA.

FAQ ID:162411

Yes, examples of approved SPAs for States that expanded services beyond IDEA services (e.g., Arizona, Colorado, Illinois, New Mexico) can be found on CMS' website at the following link: https://www.medicaid.gov/resources-for-states/medicaid-state-technical-assistance/medicaid-and-school-based-services/technical-assistance-materials/index.html

It's important to note that each State, District of Columbia, and territory is unique, and it is crucial to ensure that the SPA aligns with the specific needs and laws of the State.

FAQ ID:162416

Yes, States are expected to apply the 2023 Comprehensive Guide to Medicaid Services and Administrative Claiming guidance to all MAC programs for all entities. Both previous guidance documents issued by CMS, including the 1997 School-based Services Technical Review Guide and the 2003 School-based Administrative Claiming Guide, are superseded by the 2023 Comprehensive Guide to Medicaid Services and Administrative Claiming.

FAQ ID:162336

First, the activities must be allowable as State program administrative activities. Secondly, the State and/or claiming unit must implement a methodology to properly identify and allocate Medicaid’s portion of cost associated with the allowable State program administrative activity. Finally, the identification and allocation of this cost must be documented in the State’s Public Assistance Cost Allocation Plan (PACAP). According to 45 C.F.R. § 95.517, State Medicaid agencies (SMAs) that intend to claim for allowable administrative activities must have an approved PACAP. As the PACAP is primarily used by the Federal cognizant agency to allocate cost incurred by one direct federal awardee, yet funded by another federal awardee, there may be instances where costs applicable to allowable State program activities are incurred and funded by the SMA. In this instance, the State may identify and allocate the cost via a Medicaid Administrative Claiming (MAC) Plan and include a reference to the identification and allocation of the cost via the MAC Plan in its PACAP.

FAQ ID:162321

CMS encourages SMAs to reimburse school districts their allowable costs of conducting Medicaid and CHIP administrative activities. School districts should work with SMAs to develop a plan to document their costs so that the SMA can distribute Medicaid and CHIP FFP to school districts in proportion to each district’s relative expenditures for Medicaid and CHIP administrative activities.

FAQ ID:162326