HEALTH ISSUES

WHAT IS MSP ANN CONNELLY Supervisor, School Nursing Program, ODH ?

MSP=MEDICAID SCHOOLS PROGRAM MSP is a way that schools can receive payment from Medicaid for health-related services provided in the school setting. Some schools have used their MSP funds to hire more healthcare staff, to purchase equipment, or to use for other purposes. MSP has been available to Ohio schools since 2009. It is similar— but not identical—to the old “CAFS” program that ended in 2005. As with any other fiscal program, there are conditions that must be met for schools to receive reimbursement from MSP for healthcare services provided. MSP reimburses schools for medically necessary health services: ral or order is required prior to the service being provided, or there will be no reimbursement by MSP for the services rendered. Specific direct services covered under MSP include physical (PT), occupational (OT), and speech and language therapy (SLP); nursing services; audiology; medical equipment and supplies; medical transportation; and administrative activities such as service coordination. Medical equipment and supplies could include items such as insulin strips, modified utensils, walkers, and assistive devices if they are included on the Medicaid–eligible student’s IEP and used only in the school setting. Schools can also bill for the licensed healthcare provider’s time spent documenting and any other paperwork required for participation in the program.

1. provided to Medicaid–eligible students ages 3 to 21 years; 2. written on an Individualized Education Program (IEP); and 3. provided by a licensed healthcare professional. Only entities that have responsibility for a student’s IEP can be an MSP provider, which limits MSP to traditional public school districts and community, or charter schools. While Educational Service Centers (ESCs) and other entities may provide licensed healthcare providers and deliver care in these schools, they must work through subcontracts with school districts to deliver services on their behalf. All school-based services reimbursed by Medicaid must be ordered, referred, or prescribed by a physician or “licensed practitioner of the healing arts.” These prescribers include physicians (MD or DO), advanced practices nurses (NP or CNS), or physician’s assistants (PA) with a Medicaid National Provider Identifier (NPI) or with an “ordering, referring, and prescribing” (ORP-only) provider number. The prescriber’s name and number must be included on claims in order for the school to receive reimbursement. A medical referHOW DO WE PARTICIPATE? To participate in MSP, school staff must participate in a Random Moment Time Study (RMTS) that helps determine the amount of time spent providing services to eligible children. School healthcare providers will be contacted during the RMTS and asked three questions about what they are doing at the moment and with whom. In a process much too complicated to address here, this information is used to calculate the reimbursement rate. For further details, please see the Ohio Department of Education link in the resources at the end of this article. WHAT ABOUT SCHOOL-BASED HEALTH CENTERS? If your school is lucky enough to have a School-Based Health Center (SBHC), services provided there are NOT typically eligible for MSP reimbursement. SBHCs have other mechanisms for payment for services that are not part of MSP. WHAT IS THE FREE CARE RULE? You may have heard discussions about federal changes to what is called the Free Care Rule. Historically, schools have been unable to bill MSP for services provided to eligible students if the same services have been provided to all students for free. In late 2014, The US Department of Health & Human Services Centers for Medi-

care & Medicaid Services revisited the Free Care Rule (please see the link to the letter under Resources). Current federal guidance allows states to choose to allow reimbursement for such services if it is allowed under the State Plan Amendment (SPA). In Ohio, the current SPA does not allow for such free care reimbursement. While your colleagues in some other states may be talking about this change, as of this writing, no changes have been made in Ohio.

WHAT IS MAC? MAC=Medicaid Administrative Claiming. MAC is a mechanism that allows local public health departments to be reimbursed, in part, for their efforts that assist low-income Ohioans in enrolling in Medicaid and accessing appropriate Medicaid–covered services. Such reimbursable activities include Medicaid outreach (informing individuals about the benefits of Medicaid and how to apply for it); referral, coordination, and monitoring activities to enable individuals to access Medicaid covered services (including arranging transportation and translation services); facilitating Medicaid eligibility determinations; and system level activities such as program planning, coordination and healthcare provider relations.

If your school contracts with the local public health department to provide school nursing or other Medicaid eligible services to your students and families, that health department might be able to do MAC claiming for services provided in your school and elsewhere. Similar to the RMTS used by MSP, MAC requires a quarterly time study week to measure percentage of time spent on MAC activities and non-MAC activities. Reimbursement is based on the results of the time study. More information about MAC may be found at the link in the resources.

CAVEATS • All MSP-billed services must be provided to students who are Medicaid eligible. • All MSP-billed services must be on the Medicaid eligible student’s IEP. If a student receives healthcare services that are not included on the IEP—or if the Medicaid eligible student does not have an IEP—then MSP will not reimburse for those services. • All MSP-billed services must be performed by a licensed health professional. For example, if a Medicaid–eligible student’s IEP includes a tube feeding or medication administration that is performed by a health aide who is not licensed by the Ohio Board of Nursing, then MSP will not reimburse for those services. • If your school has a low percentage of students that are

Medicaid eligible, it may not be cost-effective for you to participate in MSP. • If you do not have a prescription or orders for healthcare services, including SLP, MSP will not reimburse for those services.

CONCLUSION While schools are not in the business of being healthcare providers, many students benefit from receiving healthcare services in the school setting. Schools may struggle with finding the funding to provide appropriate healthcare providers and services to accommodate the needs of students. For Medicaid eligible students with IEPs, MSP funding may be a way to help pay for those healthcare providers and services. In addition, if your school works with local public health to provide healthcare services, they may be able to benefit from MAC funding. Working with partners in Medicaid, public health, and education can help improve the health outcomes and academic achievement—attendance, graduation rates, test scores, etc.—of your students.

RESOURCES The Ohio Department of Education Ohio Medicaid Schools Program at http://education.ohio.gov/ Topics/Finance-and-Funding/Programs/The-Ohio-Medicaid-Schools-Program CMS Free Care Rule Letter (2014) https://www.medicaid.gov/federal-policy-guidance/downloads/ smd-medicaid-payment-for-services-provided-without-charge-free-care.pdf The Ohio Department of Health Medicaid Administrative Claiming http://www.odh.ohio.gov/about/ finmgmt/whatismac.aspx