On June 9, the U.S. Department of Health and Human Services (HHS) released details on how the Department intends to disburse funding to Medicaid providers from the provider relief fund.

Key details on the Medicaid awards: 

  • Total Amount: $15 billion for Medicaid providers.
  • Eligibility: Any provider that did not receive a funding award from the first $50 billion in awards made to providers with some level of Medicare utilization, and directly billed a state Medicaid program or Medicaid managed care plan between January 1, 2018 and May 31, 2020.
  • Process: Providers submit annual patient revenue information to HHS's provider relief fund portal by July 20, 2020.
  • Award Amounts: Minimum of two percent of gross patient care revenues, with final amount determined by provider-submitted data including number of Medicaid patients served. 


The Council of Administrators for Special Education/Let’s Go Learn has passed along the PDF slide deck from their latest webinar, Navigating Special Education and Remote Learning.  In addition to the webinar, you can also learn more about Let's Go Learn by visiting, letsgolearn.com.   



On April 3, 2020, The Healthy Student's, Promising Futures Collaborative held a conference call on what states are doing around the delivery of school health services during the COVID-19 Pandemic.  To view the resources that were shared, click on the link below:

Resources Shared on April 3 COVID Call


The U.S. Department of Health and Human Services and the U.S. Department of Education released the December 2019 Update on the Joint Guidance on the Application of the Family Educational Rights and Privacy Act (FERPA) And the Health Insurance Portability and Accountability Act of 1996 (HIPAA) To Student Health Records.  Please Click here to view the report in its entirety.



On March 2, the Centers for Medicare and Medicaid Services (CMS) published a State Health Official letter describing required access to mental health and substance use disorder services for children and pregnant women enrolled in standalone CHIP programs, as required under Section 5022 of the SUPPORT Act. 

These provisions, which became effective October 24, 2019, require child health and pregnancy related assistance to cover mental health services and behavioral health services necessary to prevent, diagnose, and treat a broad range of mental health symptoms and disorders. CMS interprets the coverage requirements to include all developmental and behavioral health related screenings and preventive services recommended by the American Academy of Pediatrics' Bright Futures periodicity schedule and any services with a grade of A or B under the U.S. Preventive Services Task Force. CMS also provides a set of validated behavioral health screening tools that would satisfy the screening requirement. 

Lastly, in order to meet the statutory implementation deadline of October 24, 2019, CMS indicates that states needing to make changes to a standalone CHIP program must file a CHIP State Plan Amendment no later than the end of the state fiscal year that includes that date.


Several states are now taking advantage of a 2014 policy change allowing school-based clinics and providers to bill Medicaid for care provides to children on the Medicaid rolls. Now that they can bill Medicaid, more schools will be able to provide a range of services to students through Medicaid, including managing chronic conditions such as asthma, diabetes, and food allergies; mental health and addiction treatment; and dental, vision, hearing, and speech services.

The full article is available here


The Kaiser Family Foundation has developed a series of state health care "snapshots" to help readers understand the health care landscape in which the 2020 election policy debates will unfold. These snapshots provide data across a variety of health policy subjects, including health care costs, health coverage-Medicaid, Medicare, private insurance-and the uninsured, women's health, health status, and access to care. They also describe each state's political environment.

The snapshots are available here.


Healthy Schools Campaign and Trust for America’s Health is excited to share the final Guide to Expanding Medicaid-Funded School Health Services. The guide provides background on school-based Medicaid and outlines various opportunities to advance state policy changes required to access federal funds. The full Guide can be accessed by clicking on the link below.



CMS Publishes Proposed Rule on Medicaid Fiscal Accountability

On November 12, the Centers for Medicare and Medicaid Services (CMS) issued a Notice of Proposed Rulemaking(NPRM) on Medicaid fiscal accountability. The NPRM covers a wide variety of Medicaid financing structures and mechanisms that CMS views as posing risks to the fiscal integrity of the program, including supplemental payment arrangements, provider taxes and donations, and sources of state share of Medicaid funding. The rule proposes a number of new reporting requirements and practices that CMS believes will give it certainty in assessing and approving state financing arrangements, and directly responds to concerns raised by federal oversight entities such as the Government Accountability Office and the U.S. Health and Human Services Office of the Inspector General.

The National Association of Medicaid Directors (NAMD) published the following overview in their November 19, 2019 Bi-Weekly Update. 

A high-level overview of the rule's topics includes: 

  • Definitions: Defines in regulation what constitutes a Medicaid "base" payment and a "supplemental" payment
  • Three-Year Sunset: Requires any supplemental payment or tax waiver to automatically sunset after three years, with state option to renew the arrangement after CMS review and approval;
  • Provider-Level Reporting: Requires states to report each provider's received supplemental payment level, the specific authority the state is using to make the supplemental payment, and the source of the state share of the supplemental payment;
  • Requirements on Provider Sources of Non-Federal Share: Clarifies that states using Intergovernmental Transfers (IGTs) or Certified Public Expenditures (CPEs) must draw the IGT or CPE from a legitimate state or local tax source; requires that providers receiving a supplemental payment retain 100 percent of that supplemental payment to prevent recycling of payments to draw down additional federal share; new requirements on ownership transfers and when such transfers do not constitute a legitimate change of ownership for purposes of additional Medicaid payments;
  • Disproportionate Share Hospital (DSH) Payments: New data elements for DSH audits to quantify individual hospital findings in the audit; new requirements on how states must either repay or redistribute identified DSH overpayments; and
  • Health Care-Related Taxes and Donations: Clarifies rules around masking impermissible tax and donation schemes to prohibit arrangements that pose undue burdens on the Medicaid program, such as taxing a managed care plan's Medicaid line of business at a significantly higher rate than other business. 

This NPRM was formally published in the Federal Register on November 18 with a 60-day comment period closing on January 17, 2020.

As noted, this NPRM covers a broad range of topics. The area that will most likely directly affect School-Based Medicaid billing is within the Requirements on Provider Sources of Non-Federal Share, specifically supplemental payments and state share match sources. 

If you have any concerns or questions, please reach out to:

John Hill, NAME Executive Director                     Amy Edwards, NAME Governmental Affairs

This email address is being protected from spambots. You need JavaScript enabled to view it.                    This email address is being protected from spambots. You need JavaScript enabled to view it.

Commonwealth of Kentucky, Cabinet for Health and Family Services (CHFS) has received final approval for a Medicaid state plan amendment that will expand health services in schools. “Approval for this amendment is a game changer,” said CHFS Secretary Adam Meier. The full release can be accessed by clicking on the following link: