In June of this year, the Centers for Medicaid and Medicare Services (CMS) approved a change for Georgia’s Medicaid program that shifts how school nurses can bill for their services. Before June, Medicaid would only pay for school health services, including nursing services, if the student had a special education plan called an Individualized Education Program (IEP). IEPs are maps that lay out a program of tailored education instruction, supports, and services. These plans are required for all students receiving special education services like students with ADHD, autism, or a speech impairment. The approved change allows Medicaid to pay for more school health services provided to any student with Medicaid coverage.
Medicaid is a partnership between the federal and state governments. Georgia largely operates Medicaid under what is called a State Plan, while CMS pays for 2/3 of program costs. Changes to Georgia’s Medicaid program, like the change described above, are usually made with a “state plan amendment” (SPA).
Georgia’s new SPA, sometimes called the “free care rule,” rolls back the requirement that students have an IEP for school districts to be paid by Medicaid for nursing services. This change means school districts can bill for school-based nursing services delivered to all Medicaid-enrolled students. Half of Georgia’s kids are covered by Medicaid or PeachCare, so this shift is dramatic and creates an opportunity to bring in hundreds of millions of Medicaid dollars to Georgia’s school districts. In addition to this newly available Medicaid funding, the state can also invest funding from the American Rescue Plan to help implement the program. (Georgia received a third installment of funding for schools, called ESSER, from the American Rescue Plan. The State Department of Education is allowed to hold on to 10% of that money to address statewide needs, which could include implementing the new SPA.)
Other states that have already implemented the free care SPA have seen a meaningful increase in Medicaid revenue, which has led to increases in school health workforce. For example, Louisiana implemented the free care SPA in 2015 and saw a 30% increase in their Medicaid revenue. During this same period, there was a 15% increase in the school nursing workforce. The increase in Medicaid revenue likely allowed school districts to hire more school nurses. Only 53% high schools, 58% of middle schools, and 66% of high schools have school full-time school nurses[1]. An increase in school health workforce like Louisiana experienced would have a big impact on many students and schools in Georgia.
Georgia’s SPA took effect immediately after CMS approved the change, and now the Georgia Department of Education (DOE), the Department of Community Health (DCH), and school districts must work together to figure out how best to implement the changes. They must address a few factors, including a change to how Medicaid services are billed, updating the documentation required for Medicaid, and spreading the word to local school districts about the change. GHF encourages DOE, DCH, and school district representatives to partner with the School Nurse Association and work together to implement the SPA effectively and efficiently. We are eager to see DOE, DCH, and school districts make the most of this opportunity so that Georgia students have increased access to health services in schools.
While Georgia’s free care SPA is a positive change, it only allows Medicaid to pay for school nursing services. All other medical services (such as physical therapy, hearing screenings, and counseling services) provided by the school still require that a student have an IEP to be reimbursed by Medicaid. Georgia is the only state with such a narrow free care SPA. Other states allow all medical and health services covered by Medicaid to be billed to Medicaid without requiring an IEP. Once Georgia’s state agencies, school districts, and partners have had time to implement this initial SPA, GHF encourages the state to submit a new SPA that would allow all medically necessary services to be billed to Medicaid without the IEP requirement. Expanding the services that can be covered for all Medicaid-enrolled students will bring more federal dollars into the state that can be invested in the health of Georgia’s children.
[1] SOURCE: U.S. Department of Education, Office for Civil Rights, Civil Rights Data Collection, 2015-16, available at http://ocrdata.ed.gov. Data notes are available at https://ocrdata.ed.gov/Downloads/Data-Notes-2015-16-CRDC.pdf
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