How State Medicaid Policy Influences Billing for "Free Care" in Public Schools

In 2014, the Centers for Medicare & Medicaid Services (CMS) issued new guidance to allow providers in educational settings to seek Medicaid reimbursement for free preventive services covered by the Early and Periodic Screening, Diagnostic and Treatment (EPSDT) benefit provided to Medicaid-enrolled children. However, following CMS’ announcement, states retained policies restricting reimbursement for these services. As of 2016, three states expressly prohibited billing, while 22 others had policies and provisions that would impede school efforts to seek reimbursement.

To help education policymakers and other stakeholders understand the state policy landscape impacting Medicaid billing for school-administered services, the research team at Child Trends and the National Health Law Program will investigate how state policy has shifted following CMS’ 2014 rule, focusing on three research questions:

1. To what extent do state policies support Medicaid billing for school-administered free care?
2. How has Medicaid billing for school-administered services shifted since CMS' reversal of the free care rule, and what is the relationship between such billing and state free care policies?
3. For states with supportive free care policies, what factors influence how districts and schools use Medicaid to support student health?

The team will conduct a content analysis of state policies, including state Medicaid plans, plan amendments, and requests for Medicaid Managed Care contract proposals (from all 50 states and DC), to identify obstacles to Medicaid billing for school-administered care. They will then analyze how Medicaid billing for school-administered services has shifted since CMS' 2014 decision, while comparing states with different policies for differences in billing. Lastly, they will interview state officials and education stakeholders in Massachusetts and Louisiana to examine how shifts in state Medicaid policy have influenced schools' capacity to support student health.