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MSP Bulletins

There is a lot going on with Medicaid both on the Federal level and in the State of Ohio, and we want to make certain that all Ohio “Medicaid School Program” (MSP) participating school districts understand and are prepared with upcoming changes to MSP. We will be informing you of these changes as the Ohio Department of Medicaid (ODM) and the Ohio Department of Education & Workforce (ODEW) release final details. This is a new series of Ohio MSP related bulletins that we will be releasing throughout the year.

Table of Contents

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  • MSP Expansion—Approved Skilled Providers

    From the desk of Dan Thomas

    Ohio Medicaid School Program Bulletin — HBS 2026-2

    Ohio Medicaid School Program Approved Skilled Providers

    Effective January 1, 2026, the following skilled service providers are eligible for Ohio Medicaid School Program reimbursement:

    • Occupational Therapy Services
    • Occupational Therapist
    • Occupational Therapist Assistant

      Student Occupational Therapist
    • Student Occupational Therapist Assistant
    • Speech-Language Pathology Services
    • Speech-Language Pathologist

      Speech-Language Pathology Aide
    • Speech-Language Pathology Student
    • Behavioral Health Services
    • Professional Counselor
    • Professional Clinical Counselor
    • Professional Clinical Counselor Supervisor
    • Counselor Trainee
    • Independent Social Worker
    • Independent Social Worker Supervisor
    • Social Worker
    • Social Worker Trainee
    • Independent Marriage and Family Therapist
    • Marriage and Family Therapist
    • Marriage and Family Therapist Trainee
    • Physical Health Services
    • Registered Nurse
    • Licensed Practical Nurse
    • Clinical Nurse Specialist
    • Nurse Practitioner
    • Physician Assistant
    • Physical Therapy Services
    • Physical Therapist
    • Physical Therapist Assistant
    • Student Physical Therapist
    • Student Physical Therapist Assistant
    • Audiology Services
    • Audiologist
    • Audiologist Aide
    • Audiologist Student
    • Behavioral Health Services cont.
    • Psychologist
    • School Psychologist
    • Psychology Trainee
    • Psychology Intern
    • School Psychology Trainee
    • School Psychology Intern
    • Independent Chemical Dependency Counselor
    • Chemical Dependency Counselor II
    • Chemical Dependency Counselor III
    • Registered Nurse
    • Licensed Practical Nurse

    If you have any questions or need further information on any of our Ohio MSP Bulletins, please contact our office at (740) 639-4218 or email at Info@teamhbs.com.

  • MSP Expansion—Approved Plans and Non-Plan Services

    From the desk of Dan Thomas

    Ohio Medicaid School Program Bulletin — HBS 2026-1

    Effective January 1, 2026, the Ohio Medicaid School Program has expanded to allow for Medicaid reimbursement for direct medical services and assessments provided to students on the following Non-IEP Care Plans:

    • 504 Plans
    • Nursing Care Plans
    • Behavioral Intervention Plans
    • Absence Intervention Plans
    • Mental Health Treatment Plans
    • Safety Plans
    • Individualized Health Plans (IHP)
    • Child and Family Centered Plans (CANS)
    • Occupational Therapy Plans
    • Physical Therapy Plans
    • Seizure Action Plans
    • Asthma Management Plans
    • Diabetes Management Plans
    • School Services Plan of Care

    To meet the “medical necessity” requirements for Medicaid reimbursement, the above Plan of Care must be attached and incorporated into the Ohio Department of Medicaid (ODM) “School Services Plan of Care”. If the Non-IEP Care Plan contains all the Medicaid required components, the only sections that need completed on the School Services Plan of Care are:

    • Page 1 — Student Demographic Information
    • Page 2 — Required Signatures
    • Page 3 — Alternative Documentation Checklist

    The Medicaid required components that need to be included in the Non-IEP Plan of Care are:

    • Description of need based on an assessment conducted by an authorized school district provider or community provider.
    • Signed by the authorized school district provider.
    • Include specific services used, and amount, duration, and frequency of each service.
    • Include specific goals to be achieved.
    • Specify timelines for re-assessment that is no more than twelve months from date of initial assessment.
    • Include specific criteria regarding referrals to community providers, when appropriate.
    • For Nursing Services, reference and identify the location of the prescription of the physician.

    See pages 4, 5, and 6 of the School Services Plan of Care for required component examples. If you incorporate these components into your existing Non-IEP Plans of care, only pages 1, 2, and 3 need to be completed on the School Services Plan of Care.

    HBS will be adding the School Services Plan of Care (link below) to our online MSP service documentation software that your therapists currently use to document their MSP services. The form can be completed, saved, and maintained in our system. The Non-IEP Plan of Care can be imported and saved in our system as well. We are also adding a School Services Plan of Care training video in our billing software along with our other MSP training videos.

    School Series Plan of Care

    School Series Plan of Care Guidance

    If you have any questions or need further information on any of our Ohio MSP Bulletins, please contact our office at (740) 639-4218 or email at Info@teamhbs.com.

  • RMTS—Increase Medicaid Reimbursement (Part 4)

    From the desk of Dan Thomas

    Ways to increase Medicaid reimbursement.

    Please see “Part 1” , “Part 2”and “Part 3”before proceeding with Part 4.

    With the changes to RMTS beginning with the 2025/26 school year, MSP Final Settlements paid in 2028 will likely decrease for contracted therapy services. To help offset any decrease in Medicaid reimbursement for contracted services and help to increase reimbursement for employed therapy services, here are ways to ensure that your district is maximizing your total MSP reimbursement:

    • Make sure that your district is billing for all MSP-covered IEP therapy services, which are: Speech and Language, Occupational Therapy, Physical Therapy, Nursing Services, Audiology Services, Psychology Services, Counseling Services, and Social Work Services.
    • Begin tracking and billing for Specialized Transportation Services. This would be for students who cannot be transported on regular buses due to their medical disability.
    • Obtain MSP Parental Consent for all students who are receiving therapy services. We cannot bill Medicaid without parental consent.
    • Apply for an “Indirect Cost Rate” (ICR) that can be used to increase your costs on your MSP Cost Report. HBS can prepare the ICR return for your district as part of our cost reporting services. The ICR is only applied to employee costs on the MSP cost report.
    • Track what your district spends on Medical Supplies and Equipment, to report on the MSP Cost Report. Medical Supplies and Equipment can be reimbursed at 50%.
    • Consider going to a “flat rate” billing fee model, which can also be 50% Medicaid reimbursable.
    • Provide Medicaid Eligibility Information to parents to encourage Medicaid enrollment. This could increase your “Medicaid Eligibility Rate” (MER) and provide health insurance coverage for eligible families.
    • Make sure that therapists are thoroughly trained on RMTS and are answering their selected moments timely and accurately. RMTS is one of the most important factors in computing overall MSP reimbursement.
    • Begin identifying administrative staff who coordinate medical services for inclusion in “Medicaid Administrative Claiming” (MAC), which will be added to MSP in the near future, hopefully the 2026/27 school year.
    • Begin completing a “School Services Plan of Care” for Non-IEP students who are receiving medical services through a 504 Plan, Nursing Care Plan, Mental Health Plan, or an Absence or Behavioral Intervention Plan. This is what is being referred to as “MSP Expansion” and will be effective beginning 01/01/2026.

    Your district should have received information from the Ohio Department of Medicaid (ODM) this week regarding the School Health Services Plan of Care. Our first MSP Bulletin of 2026 will focus on MSP Expansion and how districts can begin getting Medicaid reimbursement for Non-IEP medical services. 2026 will be an exciting year for the Ohio Medicaid School Program as we finally begin implementation of MSP Expansion.

    From our entire team at HBS, we would like to wish you and your staff a safe and happy holiday season. We look forward to working with you in 2026 to continue to maximize your MSP reimbursement.

    If you have any questions or need further information on any of our Ohio MSP Bulletins, please contact our office at (740) 639-4218, or email at Info@teamhbs.com.

  • RMTS—The Changes (Part 3)

    From the desk of Dan Thomas

    MSP Random Moment Time Study (The Changes)

    Please see “Part 1”and “Part 2”before proceeding with Part 3.


    The Centers for Medicare & Medicaid Services (CMS) made significant changes to the RMTS process for all State’s school-based Medicaid programs. For Ohio’s Medicaid School Program, those changes are effective beginning July 1, 2025. Those changes are:

    • All MSP therapists must participate in RMTS, and their costs must be factored down by the RMTS percentage on the MSP Cost Report. Previously only therapists that were direct employees of the school district participated in RMTS.
    • MSP therapists selected are now given a 2-day notice of their selected date and time, and have 2-days to respond. Previously they were given a 3-day notice and had 3-days to respond.
    • The RMTS now must be completed for all 4 quarters of the year. Previously RMTS was not required for the quarter of July, August, and September.
    • The RMTS is now only selecting 443 moments per quarter. Previously RMTS selected 3,000 moments per quarter.
    • All RMTS therapists must view an RMTS training video annually. The training video can be viewed on our website here and in our documentation system.



    The results of the 1st RMTS Quarter of July, August, September 2025 are:

    • 186 moments were performing an IEP Direct Service. (Medicaid Reimbursable)
    • 96 moments were performing a General Administrative Activity (Allocated)
    • 51 moments were performing an Educational/Social Service Activity (Non-Medicaid)
    • 23 moments were performing a Non-IEP Direct Medical Service (Non-Medicaid)
    • 6 moments were performing an Allowable Non-Lan Activity. (Medicaid Reimbursable)
    • 4 moments were performing a School Service Plan Activity. (Medicaid Reimbursable)
    • 1 Moment was performing a Medical Program Planning Activity (MAC)
    • 1 Moment was performing a Non-Medical Program Planning Activity (Non-Medicaid)
    • 1 Moment was performing a Coordination of Medical Services (MAC)
    • 443 Total Moments Sampled

    After reading Parts 1, 2, and 3, you can see that MSP reimbursement for Contracted Therapy Services has the potential of going down starting with the 2025/26 school year. RMTS Part 4 will focus on what can be done to offset this potential drop in Medicaid reimbursement and how to potentially increase future MSP reimbursement.

    If you have any questions or need further information on any of our Ohio MSP Bulletins, please contact our office at (740) 639-4218, or email at Info@teamhbs.com.

  • RMTS—The Computation (Part 2)

    From the desk of Dan Thomas

    MSP Random Moment Time Study (The Computation)

    Please see “Part 1”before proceeding with Part 2.

    Since Contracted therapy service costs will now be factored down by the RMTS percentage beginning with the 2025/26 school year, it is even more important that the RMTS process is done properly by districts and by all billing agent vendors.

    The historical RMTS rates for Ohio MSP are:

    SFY 2014 = 56.10%SFY 2017 = 35.74%SFY 2020 = 37.13%SFY 2023 = 49.08%
    SFY 2015 = 48.29%SFY 2018 = 34.74%SFY 2021 = 36.16%SFY 2024 = 55.17%
    SFY 2016 = 48.54%SFY 2019 = 34.31%SFY 2022 = 36.00%SFY 2025 = 54.25%

    Here is the RMTS computation for the 2024/25 School Fiscal Year (SFY). For this SFY, there were 3,000 moments sampled for each of the three quarters of October-December 2024, January-March 2025, and April-June 2025, for a total of 9,000 moments sampled. The results are:

    • 3,781 moments were performing an IEP Direct Service. (Medicaid Reimbursable)
    • 2,031 moments were performing a General Administrative Activity (Allocated)
    • 1,720 moments were performing an Educational/Social Service Activity (Non-Medicaid)
    • 853 moments were performing a Non-IEP Direct Medical Service (Non-Medicaid)
    • 573 moments were Not Working/Unpaid (Non-Medicaid)
    • 22 moments were performing a Medicaid Outreach Activities (MAC)
    • 20 moments were performing a Non-Medicaid Outreach Activities (Non-Medicaid)
    • 9,000 Total Moments Sampled

    After the allocation of General Administrative Activities, 4,883 of the 9000 moments were computed as IEP Direct Medical reimbursable services. 4,883/9000= 54.25%, which is the percentage that will be used on the 2024/25 MSP Cost Report. (down 1% from 2023/24)

    Now that you know what RMTS is (Part 1) and how RMTS is computed (Part 2), RMTS (Part 3) will focus on the specific changes to RMTS for SFY 2025/26.

    If you have any questions or need further information on any of our Ohio MSP Bulletins, please contact our office at (740) 639-4218, or email at Info@teamhbs.com.

  • RMTS—Overview (Part 1)

    From the desk of Dan Thomas

    MSP Random Moment Time Study

    Random Moment Time Study (RMTS) is one of the most important components of the Ohio Medicaid School Program (MSP), and there are big changes to the process/methodology for the 2025-26 school year.

    What is MSP Random Moment Time Study (RMTS)?

    RMTS is a “Time Study” that computes the “percent of time that MSP therapists spend performing Medicaid Reimbursable Activities”. MSP therapists are included in a statewide pool along with their work schedule, and are randomly selected to record what they were doing on a specific date and time. The final result is a statewide percent that is used on the MSP Cost Report to compute “MSP Reimbursable Costs” (Total MSP Reimbursement).

    Prior to the 2025-26 school year, only “district employed therapists” were included in RMTS, and “contracted therapists’” costs were not factored down by RMTS.

    There are three percentages that are applied to your total “Therapy Costs” to compute your total “MSP Reimbursable Costs” (Total MSP Reimbursement), which are:

    • RMTS “Random Moment Time Study” (Statewide)
    • MER “Medicaid Eligibility Rate” (District)
    • FFP/FMAP “Federal Financial Participation” (Statewide)

    Cost Report Computation Example:

    EmployedContracted
    Total therapy costs ($100,000)$100,000$100,000
    x RMTS (random moment time study %) *(53%)$53,000 N/A (pre-25/26)
    x MER (district Medicaid Eligibility Rate) (40%)$21,200$40,000
    x FFP/FMAP (% Medicaid reimburses) (70%) $14,840 $28,000
    Total MSP Reimbursement  $14,840 $28,000

    * 1,431 moments selected were “Medicaid Reimbursable” out of 2,700 total moments selected (1431/2700=53%)

    The biggest change to RMTS for 2025/26 is that “Contracted Therapists” will now need to be included in RMTS, and their costs will now be factored down by the RMTS statewide percentage.

    HBS 2025-8 Part 2 will be released next week with additional details on the changes to the Random Moment Time Study.

    If you have any questions or need further information on any of our Ohio MSP Bulletins, please contact our office at (740) 639-4218 or email Info@teamhbs.com.

  • MSP Parental Consent to Share Student-specific Health Information and Bill Medicaid

    From the desk of Dan Thomas

    What is MSP Parental Consent?

    The “Health Insurance Portability and Accountability Act” (HIPAA) and the Family Educational Rights and Privacy Act” (FERPA) both require that school districts obtain signed Parental Consent before sharing a student’s Personally Identifiable Information (PII) in the process of billing Medicaid.

    • Annually, an MSP Parental Consent Notification must be provided to the parent or guardian.
    • A one-time MSP Parental Consent Form must be signed by the parent or guardian.

    When to Obtain Signed Parental Consent?

    • The best time to get signed MSP Parental Consent is when the parent is signing the PR-05 Parent Consent For Evaluation. 
    • Another good time is when the parents are signing the PR-07 Individualized Education Program (IEP).
    • HBS will inform school districts on a monthly basis of students receiving therapy services that we do not yet have a signed Parental Consent Form on file. The district should attempt to obtain the missing signed parental consent form anytime that they have contact with the parent.

    How Should We Distribute the Annual MSP Parental Notification to parents?

    • Many districts have elected to post the MSP Parental Consent Notification on their district website.
    • Another method is sending the Notification home with the student to pass on to the parent.
    • US Post office mailing of the Notification to all IEP students is also an option.
    • Emailing the Notification to the parents is always an option also.

    If you have any questions or need further information on any of our Ohio MSP Bulletins, please contact our office at (740) 639-4218 or at info@teamhbs.com

  • Who performs Medicaid Administrative Claiming (MAC) activities in your district?

    From the desk of Dan Thomas

    Ohio Medicaid School Program Bulletin — HBS 2025-5

    Medicaid Administrative Claiming (MAC) reimburses school districts for the administrative costs of “Referring, Coordinating, and Monitoring of students Medical, Therapy, and Mental Health Services”. We are already capturing these costs for licensed therapists such as OTs, PTs, SLPs, Psychologists, Social Workers, and Licensed Counselors. MAC reimburses for the “Care Coordination” services provided by administrative non-licensed staff such as:

    Therapy Supervisor (not doing direct therapy)
    Special Education Director
    Health or Nursing Assistant
    Intervention Specialist
    Office Manager
    Program Coordinator

    We are working with our time study vendor Sivic Solutions to develop a list of “Job Titles” to include in the MSP Time Study Guide. We would like to know the Job Titles of the individuals in your district that would provide the following services for your students:

    • Refer adolescents for family planning services.
    • Make referrals for medical, therapy, and mental health evaluations.
    • Refer and schedule EPSDT screens and immunizations.
    • Refer students for medical, therapy, mental health, and substance use services.
    • Arrange for medical, therapy, and mental health diagnostic or treatment services.
    • Gather the required information for medical, therapy, and mental health referrals.
    • Participates in meetings/discussions to coordinate or review a student’s need for health-related services.
    • Follows-up to ensure that a student receives the prescribed medical, therapy, and mental health services.
    • Coordinate with community the medical, therapy, and mental health services for a student.
    • Coordinate the completion, termination, referral required to provide continuity of care.
    • Monitor and evaluate the medical components of the IEP.
    • Coordinate the medical, therapy, and mental health service provision with students Managed Care Plan (MCP).

    Each school district is set up differently, and we want to make certain that we have the Job Titles in the MSP rules that are consistent with whom in Ohio school districts provide MAC activities. We will be sharing more detailed information on MAC as we get the MSP Time Study Guide updated but first would like to get the correct positions identified.

    Thank you in advance for your valuable input.

    What job positions/titles in your school district “Refer, Coordinate, and Monitor” Medical, Therapy, and Mental Health Services?

    REPLY HERE

    If you have any questions or need further information on any of our Ohio MSP Bulletins, please contact our office at (740) 639-4218 or email at Info@teamhbs.com.

  • MSP Expansion—Overview

    From the desk of Dan Thomas

    Ohio Medicaid School Program Bulletin — HBS 2025-4

    The Ohio Medicaid School Program is governed by “The Centers for Medicare and Medicaid Services” (CMS). CMS is a federal agency and is part of the “US Department of Health and Human Services” (HHS). CMS oversees various healthcare programs such as Medicare, Medicaid, Children’s Health Insurance Program (CHIP), and the Health Insurance Marketplace.

    In 2023, CMS issued updated guidance for “School-Based Medicaid Programs” releasing a new program guide called: Delivering Services in School-Based Setting: A Comprehensive Guide to Medicaid Services and Administrative Claiming.

    You can download a copy here: https://www.medicaid.gov/medicaid/financial-management/downloads/sbs-guide-medicaid-services-administrative-claiming.pdf

    Each state’s school-based Medicaid program must comply with this new guidance by July 1, 2026. We are currently collaborating with the Ohio Department of Medicaid (ODM), the Ohio Department of Education and Workforce (ODEW), Sivic Solutions (time study vendor), and other key stakeholders to design and implement the required updates. While some of these changes present opportunities to increase Medicaid reimbursement, others may result in reduced MSP reimbursement. Final decisions will depend on the approval of Ohio’s State Plan Amendment (SPA) by both state officials and CMS. Below are a few of the changes currently under development:

    • Expanded Eligibility Beyond IEPs
      Reimbursement will no longer be limited to services provided under an Individualized Education Program (IEP). Under the new rules, Medicaid will now reimburse for therapy services delivered to students with 504 Plans, nursing care plans, mental health plans, or other qualified health service plans. Currently, MSP reimbursement is limited to students on an IEP.
    • Reimbursement for Medicaid Administrative Claiming (MAC)
      A more accessible Medicaid Administrative Claiming (MAC) service is being added. Although MAC has historically been part of MSP, it was narrowly defined. Barriers are being removed, and clearer guidelines will be provided to support implementation.
    • Significant Changes to Random Moment Time Study (RMTS)
      To comply with CMS’s updated requirements, the RMTS methodology will undergo three major updates:
    1. Inclusion of Contracted Therapists
      Previously, only district-employed therapists participated in RMTS; contracted therapists were excluded. The new CMS guide requires contracted therapists to participate in RMTS, and their costs factored down using the RMTS percentage, as is currently done with employed therapist costs. This change is likely to decrease reimbursement for contracted services.
    2. Four-Quarter Time Study Implementation
      RMTS is currently conducted in three school-year quarters (Oct–Dec, Jan–Mar, Apr–Jun), with no time study during the summer quarter (Jul–Sep). The updated rules will require year-round RMTS participation, covering all four quarters.
    3. Reduced Notification and Response Time
      The advance notice and response window for selected RMTS participants will be shortened from three days to two days, aligning with new CMS expectations.

    Timeline & Recommendations

    Some elements of the MSP Expansion may be approved and available as early as the 2025–26 school year. We recommend the following phased approach:

    • Delay RMTS changes until July 1, 2026, allowing districts time to prepare for the transition.
    • Begin gradual rollout of MAC and Non-IEP services during the 2025–26 school year.

    Our objective is to ensure that any potential decrease in reimbursement caused by RMTS changes is outweighed by increased funding through MAC and services for students without IEPs.

    Stay tuned to future MSP Bulletins for updates on the expansion and the implementation process.

    If you have any questions or need further information on any of our Ohio MSP Bulletins, please contact our office at (740) 639-4218 or email at Info@teamhbs.com.

  • “School-Based Practitioners” (SBP) Summit

    From the desk of Dan Thomas

    In 2017, former State School Board members Michael Collins, Bryan Williams, and myself formed the Ohio School Health Services Association (OSHSA). www.oshsa.org

    Our association was formed to help promote the growth and success of the school-based health programs and services in Ohio schools. One of our main events is the annual “SBP Summit” scheduled for August 11 and 12 at the Hilton Columbus-Polaris. Over 500 OTs, PTs, and SLPs from school districts across the state will be in attendance networking and experiencing the great lineup of speakers. HBS is a major sponsor of this event, and we will have a booth there to answer any questions your therapists may have.

    This popular conference will fill fast, so please have your therapists sign-up early. They will earn 12 CEU credit hours for attending our summit. More info and registration can be found at www.SBPsummit.com.

    If you have any questions or need further information on any of our Ohio MSP Bulletins, please contact our office at (740) 639-4218 or email at Info@teamhbs.com.