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States Expand Medicaid Reimbursement of School-Based Telehealth Services

 width=During the COVID-19 pandemic, students have faced disruptions in access to school-based physical and behavioral health services as schools shifted from in-person to virtual learning. Many schools adapted by delivering services through telehealth and states implemented policies that allow Medicaid to reimburse for school-based telehealth services to support the health needs of students. These policies promote access to critical health services for students and support schools in meeting federal requirements to provide services to students with disabilities while reducing risk of COVID-19 transmission. This issue brief, States Expand Medicaid Reimbursement of School-Based Telehealth Services, discusses these policies and key considerations for states during and beyond the pandemic.
 
These maps and the accompanying chart highlight the types of school-based telehealth services that states reimbursed through Medicaid prior to COVID-19, and policy changes during the pandemic. 

Medicaid Reimbursement Policy for School-Based Telehealth

Chart

Key Terms

AS – Audiology Services

BH – Behavioral health

DS – Distant site (service provider is located in the school)

EPSDT – Early and Periodic Screening, Diagnostic, and Treatment

IEP – Individualized Education Plan

LEA – Local Education Agencies

NS – Nursing Services

OS – Originating site (student receiving services is located in the school)

OT – Occupational therapy

PCS – Personal care services

PS – Physician Services

PT – Physical therapy

SLT – Speech/language therapy

StatePre-COVID-19 Medicaid reimbursement policies for school-based telehealth servicesMedicaid reimbursement for school-based telehealth services policy changes during COVID-19State guidance on Medicaid reimbursement for school-based telehealth services
AlabamaClinically appropriate Medicaid reimbursable IEP services–––·       LEA Provider Manual (January 2021)
Alaska **–––BH, OT, PT, SLT·       Temporary Expansion of Medicaid Telemedicine Coverage (March 2021)
Arizona–––

BH, OT, PT, SLT

Some services allowed during COVID-19 will be permanent, while others will be temporary

·       Arizona Health Care Cost Containment System Telehealth Services

·       Frequently Asked Questions (FAQs) Regarding Coronavirus Disease 2019 (COVID-19) (January 2021)

·       School Based Claiming: Telehealth Services (April 2020)

Arkansas **–––All IEP Services

·       Use of Telemedicine to Provide Occupational, Physical and Speech Therapy during COVID-19 Outbreak (March 2020)

·       Guidance for School-Based Therapy Service Delivery during COVID-19 Outbreak Medicaid in the Schools (April 2020)

·       School Health Services COVID-19 School Closure Guidance

CaliforniaSLT

All EPSDT Services

California is proposing to make these changes permanent.

·       Temporary directive (April 2020)

·       Policy and Procedure Letter 20-014R (September 2020)

·       Local Educational Agency Medi-Cal Billing Option Program (October 2020)

·       LEA Billing, Provider Manual (September 2018)

ColoradoBH, PCS, PS, PT, NS, OT, SLT–––·       School Health Services Program Manual: Covered Services (2020)
Connecticut–––BH, PT, OT, SLT·       CMAP COVID-19 Response – Bulletin 11: Emergency School Based Child Health (SBCH) Program Changes (March 2020)
DelawareBH, EPSDT assessment, OT, PT, SLT–––

·       Changes to Telehealth Policies to Respond to COVID-19 (April 2020)

·       School Based Health Services Provider Policy Manual (August 2018)

District of Columbia **

DS: –––

OS: BH, SLT

–––

·       Telemedicine Provider Guidance (March 2020)

·       Medicaid Reimbursement Guidelines for Participating Local Education Agencies

Florida **–––OT, PT, SLT, BH·       Memorandum: Mental and Behavioral Health and Telehealth Services for Florida Students (May 2020)
Georgia **

DS: –––

OS: PT, SLT

 

–––

·       Telehealth Guidance for Medicaid/PeachCare Kids/Fee-for-service Providers (March 2020)

·       Telemedicine Guidance Policy Manual (October 2020)

HawaiiAll IEP services: BH, NS, OT, PT, SLT–––

·       HI Rev Stat § 346-59.1 (2017)

·       School-based Medicaid Claiming Program, Special Education, Hawaii Department of Education

Idaho–––All IEP services including AS, BH, OT, PT, SLT

·       Guidelines for Providing Medicaid School-Based Services During the COVID-19 Pandemic (April 2020)

·       Medicaid School-Based Services Guidance for Back-to-School (August 2020)

·       Idaho Medicaid Provider Handbook (July 2019)

Illinois **–––

DS: All IEP services including AS, BH, OT, PT, SLT

OS: –––

 

·       Provider Notice: Telehealth Services Expansion Prompted by COVID-19 (March 2020)

·       FAQs for Illinois Medicaid Virtual Healthcare Expansion/Telehealth Emergency Rules (May 2020)

·       Handbook for LEAs (February 2014)

Indiana **–––All IEP services except audiology, PT, and transportation

·       School-Based Medicaid (December 2020)

·       Medicaid Medical Billing of Health-related IEP Services (December 2020)

Iowa

DS: –––

OS: BH

All IEP services clinically appropriate to be delivered via telehealth

·       COVID-19 Provider FAQs: Telehealth

·       SF 2261 (2020)

KansasAS, SLTAll IEP services

·       Bulletin 20062: Expansion of Telemedicine Services Allowed by ECI and LEA Providers During COVID-19 Emergency (June 2020)

·       Kansas Medical Assistance Program, Fee-for-Service Provider Manual: Local Education Agency (January 2020)

KentuckyBH, NS, OT, PT, SLTAll clinically appropriate services delivered via telehealth during the public health emergency were eligible for reimbursement.·       Kentucky Medicaid School Based Technical Assistance Guide 2020-2021 (December 2020)
Louisiana–––BH (only for school-based health centers that are licensed behavioral health service providers)

·       Handbook for School-Based Medicaid Services (October 2016)

·       Informational Bulletin 20-4: Telemedicine/Telehealth Facilitation of Mental Health Rehabilitation Services During the COVID-19 Declared Emergency (October 2020)

MaineAll IEP services clinically appropriate to be delivered via telehealth–––

·       MaineCare in Education Billing Guide 2020 (November 2020)

·       Back to School Guidance 2020 (September 2020)

Maryland **IEP/IFSP Service CoordinationBH, PT, OT, SLT and nutritional counseling

·       Telehealth Guidance for School-Based Health Centers during the COVID-19 Public Health Emergency (September 2020)

·       Maryland Medical Assistance EPSDT & School Health-Related Services Billing Instructions (July 2020)

·       Maryland Medical Assistance Program IEP/IFSP Provider Alert

Massachusetts **–––

Any services deemed clinically appropriate: AS, BH, EPSDT, dental services, NS, OT, PCS, PS, PT, SLT

May be permanent pending potential policy changes

·       School-Based Medicaid Program COVID-19 Telehealth Q&A (March 2020)

·       Guidance on selected school health regulations during the COVID-19 Public Health Emergency (August 2020)

·       MassHealth School-Based Medicaid Program: Direct Service Claiming (DSC) Program Guide (August 2020)

·       School-Based Medicaid Program LEA Covered Services & Qualified Practitioners (July 2019)

Michigan

DS: AS, SLT

OS: –––

DS: BH

OS: AS, BH, SLT

Policy changes made permanent

·       Public Act 101 of 2020 (June 2020)

·       Medicaid Provider Manual (January 2021)

·       Michigan Medicaid Policy Information Sheet (January 2018)

MinnesotaAll IEP Services–––

·       Question 14 in Special Education and COVID-19 Q&A- Minnesota Department of Education (August 2020)

·       2020-21 Planning Guidance for Minnesota Public Schools (January 2021)

·       Minnesota Provider Manual, COVID-19 (February 2021)

Mississippi

OS: SLT, OT, PT

DS: –––

DS: SLT, OT, PT·      Mississippi Medicaid State Plan
Missouri **OT, PT, SLT, BH–––

·       Missouri School Boards’ Association’s Pandemic Recovery Considerations: Re-Entry and Reopening of Schools (August 2020)

·       SB 579 (2016) allows schools to receive Medicaid reimbursement for services delivered via telehealth

Montana–––All Montana Medicaid covered services that are medically necessary and clinically appropriate for delivery via telemedicine/telehealth, comport with guidelines in provider manual, and are not a service required to be face-to-face

·       School-Based Services Manual (March 2020)

·       FAQs on Telemedicine / Telehealth

·       Suspension of Face-to-Face Requirements for Some Medicaid Programs (April 2020)

·       Medicaid Coverage and Reimbursement Policy for Telemedicine/Telehealth (March 2020)

NebraskaAll school-based services, excluding nursing, personal assistance, and transportation–––·       General Statewide Telehealth – COVID-19 FAQs (April 2020)
Nevada **–––Clinically appropriate services within the health care professional’s scope of practice·       Transmittal Letter: Medicaid Services Manual Changes, Chapter 2800 – School Health Services (March 2020)
New Hampshire **–––All direct services that would have previously been rendered and Medicaid covered as face-to-face, including both medical and behavioral health services·       NH Medicaid to Schools Supplemental Fact Sheet COVID-19 Preparedness and Response (May 2020)
New Jersey **–––All related IEP services, including but not limited to, counseling, OT, PT, NS, SLT·       Providing Special Education and Related Services to Students with Disabilities During Extended School Closures as a Result of COVID-19 (April 2020)
New Mexico **All IEP Services–––·       New Mexico Administrative Code 8.310.2
New York **–––All School Supportive Services·       FAQs on Medicaid Telehealth Guidance during the COVID-19 State of Emergency (May 2020)
North Carolina **–––AS, OT, PT, SLT, BH·       Virtual Related Services: Guidance & Resources for Providers in NC Public Schools (June 2020)
North DakotaAll IEP Services–––

·       North Dakota Medicaid Provider Manual (April 2021)

·       North Dakota Medicaid COVID-19 Temporary Telehealth Policy (March 2020)

Ohio

OS: AS, OT, PT, SLT, NS, BH, limited transportation and TCM services when included in student’s IEP

Other telehealth services (e.g., DS services) may be reimbursed through contracts and/or special programming

All Medicaid School Program services included in student’s IEP

·       Telehealth Guidelines for Service Providers (August 2020)

·       Ohio Administrative Code 5160-35: Medicaid School Program;

·       Ohio Final Rule 5160-1-18: Telehealth;

·       Ohio School Based Health Toolkit (including Healthy Student Profiles http://education.ohio.gov/Topics/Student-Supports/School-Based-Health-Care-Support-Toolkit;

·       Telehealth Billing Guidelines in Response to COVID

Oklahoma **–––BH, SLT, OT, PT·       FAQ – Expanded Use of Telehealth for School-Based Health Services During COVID-19
OregonEligible school based health services per an IFSP/IEP–––

·       Telemedicine/Telehealth Coverage during the COVID-19 Emergency: Guidance for Public Education Providers Billing Oregon Medicaid for School-Based Health Services (April 2020)

·       Physical Therapy and Telehealth in Schools FAQ (February 2021)

·       Occupational Therapy and Telehealth in Schools FAQ (December 2020)

·       School Speech-Language Pathology and Telehealth FAQ (December 2020)

·       School Nursing and Telehealth FAQ (October 2020)

·       Telemental Health in Schools (October 2020)

·       Oregon Health Authority, Health Systems Division: Medical Assistance Programs, Division 133: School-Based Health Services

Pennsylvania **–––OT, PT, SLT, Social Work and Counseling·       Providing Direct Services via Telemedicine in the School-Based ACCESS Program (SBAP) During the COVID-19 Emergency (April 2020)
Rhode Island **–––––––––
South Carolina–––SLT, PT, OT·       South Carolina Department of Education Office of Medicaid Services FAQs- Providing Medicaid Telehealth Services (April 2020)
South DakotaSLTPT, OT, BH

·       South Dakota Medicaid Billing and Policy Manual: School Districts (December 2020)

·       South Dakota Medicaid Billing and Policy Manual: Telemedicine Services (January 2021)

Tennessee–––PT, SLT, OT

·       School Reopening Toolkit: Teleservices (June 2020)

·       TennCare Billing Manual: TN School Districts

·       Memo to MCOs – Telehealth and Telephone Extension (February 2021)

Texas

DS: –––

OS: OT and SLT

AS, BH, OT, PT, SLT, PS

·       COVID-19 SHARS and MAC Program FAQs

·       SHARS Services Provided Through Telemedicine or Telehealth (April 2020)

·       Texas Medicaid Provider Procedures Manual – Children’s Services Handbook (Section 3 School Health and Related Services) (March 2021)

Utah **–––Any covered Medicaid related service that is clinically appropriate and does not require hands-on care·       Utah Medicaid Guidance: Distance Education Q&A for COVID-19 Emergency
Vermont–––All previously Medicaid reimbursable IEP services

·       Virtual Special Education Services Reimbursable Through Medicaid FAQ (March 2020)

·       School-Based Health Services and Education Medicaid Telemedicine during Continuity of Learning FAQ (May 2020)

Virginia **

DS: SLT

OS: –––

AS, BH, NS, OT, PT, SLT·       VDOE Special Education and Student Services FAQ (October 2020)
WashingtonAll IEP Services–––

·       School-Based Health Care Services COVID-19 Billing FAQ (January 2021)

·       School-Based Health Care Services Billing Guide (October 2020)

West Virginia **PT, OT, SLT, BH–––·       West Virginia Health & Human Resources, Bureau for Medical Services, CH 538 School Based Health Services- 538.9 Telehealth (August 2019)
WisconsinAll clinically appropriate IEP services except transportation and attendant care when telehealth is identified as an appropriate modality in the IEP–––·       Teleservice Considerations for Related Services During the Current Public Health Emergency (October 2020)
Wyoming–––––––––

TOTAL

(51)

AS: 3

BH: 8

NS: 3

OT: 8

PCS: 2

PS: 1

PT: 8

SLT: 15

IEP: 10

EPSDT: 0

AS: 3

BH: 14

NS: 1

OT: 13

PCS: 0

PS: 1

PT: 13

SLT: 11

IEP: 10

EPSDT: 6

Other: 3

Provider manuals: 22

 

Laws and regulations: 7

 

COVID-19 guidance: 63

 

Other guidance: 8

      

**The information NASHP compiled about this state was not confirmed by the state’s Medicaid agency.

Acknowledgements: This issue brief was supported by the Health Resources and Services Administration (HRSA) of the US Department of Health and Human Services (HHS) under grant number U2MOA39467 the National Organizations of State and Local Officials co-operative agreement. This information or content and conclusions are those of the authors and should not be construed as the official position or policy of, nor should any endorsements be inferred by HRSA, HHS or the US government.

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