Federal Deferral of California’s School MAA Claims

On June 26, 2012, the federal Centers for Medicare and Medicaid Services (CMS) asked the state of California to re-evaluate unpaid school Medi-Cal Administrative Activities (MAA) claims and to change the reimbursement program claiming methodology for fiscal year 2012/13. Following several revisions to the implementation timeline, California began a new claiming methodology - RMTS - on January 1,...

Medicaid’s Free Care Practice – Resolved in 2014!

For years, a federal payment practice known as the free care rule had prevented schools from billing Medicaid for otherwise eligible health services if those same services were provided to non-Medicaid beneficiaries at no cost. This issue resolved by the federal Centers for Medicare and Medicaid Services (CMS) in December 2014. Free Care Resolution, December 2014 On December 15, 2014, CMS...

Third Party Liability in Medicaid

The Medicaid program by law is intended to be the payer of last resort for health services to individuals with dual insurance coverage. A 2006 G.A.O. report cites that this population represents approximately 13% of Medicaid recipients at any given time during the year. Medicaid requirements for billing services to this population can block otherwise eligible reimbursements for school health...

RMTS for California’s School MAA Program – Closed in January 2015

On June 27, 2014, California's Department of Health Care Services (DHCS) received conditional approval from federal CMS for a new state plan for the school Medi-Cal administrative activities (MAA) program. This new plan utilizes a new method of capturing reimbursable time and costs called Random Moment Time Sampling (RMTS), which schools implemented on January 1, 2015. School MAA Launches New...

California’s Healthy Families Program Transition – Closed in September 2013

In January of 2013, California began a year-long transition of more than 800,000 children from the Healthy Families program to the Medi-Cal program. Each of the four transition phases, which group the roughly 860,000 current Healthy Families beneficiaries by plan type and region, is contingent on federal approval to ensure continuity of care and other quality and access metrics are maintained...

Parental Consent Under IDEA

New federal regulations dictating parental consent requirements under the Individuals with Disabilities Education Act (IDEA) were issued in February of 2013, providing greater access to reimbursement for special education health services provided by schools. Previously, regulations for parental consent under 34 CFR § 300.154(d) (iv) (A) had stated that a school must obtain consent each time that...

Transportation Billing in California

California regulations previously prevented school districts from receiving federal reimbursement for eligible transportation services when provided to students that did not require the use of a wheelchair or transportation in the prone or supine position. In September 2012, Governor Brown signed AB 2608 (Bonilla) into law, temporarily expanding transportation billing for schools under the LEA...

Speech-Language Equivalency

In California, speech-language equivalency refers to an opinion issued by the state Attorney General in 2006 acknowledging that certain types of credentialed speech language pathologists (SLPs) were equivalent to the federal standard for speech pathologists, and the efforts made to incorporate this equivalency by removing restrictive billing requirements on credentialed SLPs participating in the...

Reinvesting Medicaid Payments in California

To support provision of school health services, Local Education Agencies (LEAs) often reinvest their Medicaid reimbursements in additional health treatments and administration costs. The state of California recently amended reinvestment rules that had negatively affected Medicaid reimbursements. California's Department of Health Care Services (DHCS) has changed internal rules that restricted...