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November 28, 2006
 
 
 
MEDICAID INFORMATION RELEASE #2006-42
 
TO:                 School Districts, Charter Schools, and the Idaho Infant Toddler Program;
                         Developmental Disabilities Agencies (DDA); and
                         Psychosocial Rehabilitation (PSR) Agencies
 
FROM:           Leslie M. Clement, Administrator
 
SUBJECT:     MEDICAID BILLING POLICY FOR REHABILITATIVE SERVICES PROVIDED IN SCHOOLS
 
Medicaid has had a long-standing policy that only schools may bill Medicaid for services provided in those schools.  It has come to our attention that some Developmental Disabilities Agencies (DDA) and Psychosocial Rehabilitation (PSR) agencies have been billing Medicaid directly for services they provide in schools.
 
Schools are federally obligated to provide free and appropriate public education to all children and must meet the individualized needs of each child.  If a child requires specialized services, then the school must assure that the child receives them.  Schools may meet this obligation in a variety of ways, including using their own staff or contracting with a private DDA or PSR agency.  Schools can then bill Medicaid for many of these services to recoup expenses.
 
Both schools and state Medicaid agencies are under increased federal scrutiny for both school-based services and rehabilitative services.  These are important service areas and we must ensure that billing is within applicable federal and state guidelines to maintain federal funding of these services.
 
In order to better communicate the billing policy for school-based services, Medicaid has modified the school-based services section in IDAPA 16.03.09, “Medicaid Basic Plan Benefits.”  During the public comment period on these rule changes, stakeholders recommended additional language in the DDA and PSR agency sections of IDAPA 16.03.10, “Medicaid Enhanced Plan Benefits” to make billing limitations explicit.  That additional language will be published in the January edition of the Idaho Administrative Bulletin.
 
Rules Added to Clarify Billing Policy
IDAPA 16.03.09.245
Only school districts, charter schools, and the Idaho Infant Toddler Program can be reimbursed for the services described in Sections 850 through 856 of these rules.
 
IDAPA 16.03.10.124.05.c
Prior to delivering any services in a school-based setting, the PSR agency must have a contract with the school or the Infant Toddler program.  The PSR agency must not bill Medicaid or the Medicaid participant for these contracted services.  Only the school district, charter school, or the Idaho Infant Toddler program may bill Medicaid for these contracted services when provided in accordance with IDAPA 16.03.09 “Medicaid Basic Plan Benefits,” Section 850 through 856.
 
IDAPA 16.03.10.653.05.e
Prior to delivering any services in a school-based setting, the DDA must have a contract with the school or the Infant Toddler Program.  The DDA must not bill Medicaid or the Medicaid participant for these contracted services.  Only the school district, charter school, or the Idaho Infant Toddler program may bill Medicaid for these contracted services when provided in accordance with IDAPA 16.03.09 “Medicaid Basic Plan Benefits,” Sections 850 through 856.
 
Providers may review the requirements for school-based services in the “Medicaid Basic Plan Benefits” chapter online at http://adm.idaho.gov/adminrules/rules/idapa16/0309.pdf and the requirements for DDAs and PSR agencies in the “Medicaid Enhanced Plan Benefits” chapter at http://adm.idaho.gov/adminrules/rules/idapa16/0310.pdf.  If you have questions about this billing policy or the rule changes made to clarify this policy, please contact Shannon Carlin at the Division of Medicaid at (208) 364-1903.  Thank you for your continued participation in the Idaho Medicaid program.
 
LMC/sc