DHCS Publishes New LEA Billing FAQs

As a follow-up from the Fall 2016 LEA Billing DHCS training held last October, DHCS has released a list of frequently asked questions (FAQs) and answers on various program policies.

Below, we’ve included a handful of questions and answers from the document that LEAs may find particularly interesting, specifically regarding:

  • RMTS for LEA Billing
  • Free Care (Non-IEP) Service Billing
  • Parental Consent & OHC
  • OT and PT Prescriptions
  • Heath Aide Services


It’s important to note that FAQs are often updated by DHCS throughout the year, so consider the following guidance current as of the publishing date, February 14, 2017. You can find the complete Fall 2016 Training FAQs on the DHCS website.

Nursing & Health Aide Services

Q5. If more than one Trained Health Care Aide (THCA) provides 15-minutes of services throughout the day on the same student, which THCA’s name is that service billed under, and how would this be reported in the Cost and Reimbursement Comparison Schedule (CRCS)?

  • A5. …School Health Aide Services are represented by procedure code T1004 and there is no requirement on the claim to distinguish the practitioner that provided the service… The LEA should only submit one claim for the School Health Aide Services, with the total number of units in the “Service Units” field. The LEA would need to keep backup documentation to support the total units billed and this would include information on the two practitioners providing the services, including time in and out for each provider so that the LEA can ensure that two THCAs are not billing for the same service unit. In addition, the LEA should ensure that they are not combining the THCA’s total minutes when determining how many units of service to bill, and are separately determining how many units were provided by THCA A versus THCA B. On the CRCS, the LEA will report the total salaries, benefits and other costs associated with all THCAs that have billed for services in the LEA Program.

Occupational & Physical Therapy Services

Q25. Is a student’s primary physician required to write the prescription for OT or PT services?

  • A25. DHCS is reviewing policy regarding this issue and will notify LEAs once the answer is vetted and approved.


Q28. Why would an auditor want the Medi-Cal ID number? We do not know if a student has Medi-Cal when we bill for services and there could be confidentiality issue with putting a Medi-Cal ID number on a service log.

  • A28. The Medi-Cal ID number helps to clearly identify a student, and assures that the documentation supporting the claim pertains to the correct student… DHCS will research updating loc ed a prov 8 to consider removing the student’s Medi-Cal identification number requirement in the LEA Program Provider Manual. MRB would not automatically disallow a claim if the student is clearly identified in some other way (i.e. full name plus date of birth, student number, teacher and room number, etc.)

Parental Consent and Other Health Coverage (OHC)

Q34. Do LEAs need to obtain consent from parents for providing non-IEP services?

  • A34. No. LEAs do not have to obtain parental consent to bill Medi-Cal before providing non-IEP/IFSP services to Medi-Cal eligible students, since this consent is provided during the Medi-Cal application process. However, students with services covered under IDEA (under an IEP/IFSP) do require parental consent, since IDEA created a statutory requirement to obtain parental permission before billing a Medicaid program (34 CFR 300.154).


Q38. Can billing Medi-Cal for school-related services affect the parent’s lifetime benefits or maximums?

  • A38. No. Under the Affordable Care Act (ACA), there are no lifetime benefit maximums. Additionally, Medi-Cal eligible individuals’ participation in the LEA Program will not decrease available lifetime coverage or any other insured public benefit, and will not increase premiums or lead to discontinuation of public benefits or public insurance.

Free Care Services

Q39. Can we bill for students who do not have an IEP, but have plans of care, Individual Health Care Plans or 504 Service Plans?

  • A39. Yes. However, services rendered to a student who does not have an IEP/IFSP are limited to a maximum of 24 services per 12-month period per student. Students with care plans or 504 plans are also subject to this same limitation. All program policies, guidelines, OHC requirements and restrictions listed in the LEA Program Provider Manual are still applicable to non-IEP/IFSP services

Random Moment Time Survey (RMTS)

Q42. Now that LEA billing and RMTS are coming together, will the LECs and LGAs be taking over the LEA Program?

  • A42. No, Local Education Consortiums (LECs) and Local Government Agencies (LGAs) will only be providing support for the RMTS process. They will not be responsible for other aspects of LEA Program requirements or policies, such as completion of the CRCS or interim claiming. The tasks on slide 68 (FY 2016-17 LEA Training) are examples of areas where LECs and LGAs will provide guidance to the LEAs under RMTS.


Q44. For districts who are already participating in the SMAA RMTS, will the LEA Program RMTS be facilitated through the current RMTS Software System Platform?

  • A44. Although DHCS is still in the process of finalizing the logistical issues of a combined RMTS, it is expected that the current software platform will be revised to incorporate both School-Based Medi-Cal Administrative Activities (SMAA) and LEA Program requirements. DHCS will work with CMS to determine LEA Program integration details and will keep LEAs informed as information becomes available.


Q45. Will RMTS percentages be district only or will it be by region as it is now?

  • A45. Pending CMS approval, DHCS anticipates that the RMTS percentages will be determined on a regional basis, as is currently the case with the SMAA RMTS.


Q46. How will LEA’s get their RMTS moment percentages? If by LECs/LGAs, will districts have to incur further costs for this information related to the LEA Program?

  • A46. Although this is still being finalized, DHCS expects to publish the RMTS percentages by region on the LEA Program website for LEAs to use in the completion of their CRCS.


Q47. If an LEA only participates in the Billing Option Program and not SMAA, how will that impact RMTS?

  • A47. Participation in both programs is voluntary. However, DHCS encourages participation in both programs, and with an integrated RMTS system, it is easier to participate in both programs. If an LEA chooses only to participate in the LEA Program RMTS, DHCS anticipates that they will still need to contract with their regional LEC/LGA, who will administer the RMTS process. More information on this will be forthcoming.