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:
- 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. - 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. - 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.