MSP Bulletins

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.

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 hereand in our documentation system.

The results of the 1^st 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 the allocation of General Administrative Activities, 237 of the 443 moments were computed as IEP Direct Services. 237/443=53.60%. This is actually good news in that the RMTS percentage stayed relatively the same even with the above changes.

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.

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.

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:

	Employed	Contracted
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.

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.

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

Both the Parental Consent Form and the annual Parental Consent Notification have been slightly changed, so please begin using the new forms (at links) as soon as possible.

When to Obtain Signed Parental Consent?

• The best time to get signed MSP Parental Consent is during enrollment.
• Other good times are when the parent is signing the PR-05 Parent Consent For Evaluation, when the parents are signing the PR-07 Individualized Education Program (IEP), or when parents are signing the School Services Plan of Care (SSPOC) signature page,
• 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.