If you feel like the ground has been shifting under your Medicaid School Program (MSP) lately, you’re not imagining it. Since last summer, Ohio school districts have been navigating a wave of changes: some are creating real revenue opportunities, and some are raising legitimate concerns about the future. This post breaks it all down, including what happened, when it happened, and what you should be doing about it.
Why This Moment Matters
Over 700,000 Ohio students, nearly half of all public school enrollment, are enrolled in Medicaid. The MSP isn’t a niche program. It’s one of the most significant funding streams available to districts for health services, and it pays for the people on the front lines of student wellness: school nurses, speech-language pathologists, occupational and physical therapists, counselors, and psychologists.
For context: nationally, Medicaid provides an estimated $7.5 billion per year to K-12 schools. In Ohio alone, 87% of school districts participate in MSP. Changes to this program ripple through staffing decisions, IEPs, and student outcomes.
Here’s what’s changed, and when.
The Timeline for Ohio’s New MSP Rules
- MSP operations transfer from DEW to ODM
- Every district must appoint a formal MSP Coordinator
- RMTS response window: 5 days → 48 hours
- Contracted providers now included in RMTS
- New 4th quarter added: July–September now billable
- ODM routes all communications through coordinator role
- $1 trillion in federal Medicaid cuts over 10 years
- ~$100 billion per year nationally
- Ohio projected to lose $5B+ over 10 years
- $202M rural health grant — partial offset only
- Eligibility restrictions reduce enrolled student counts
- School-based Medicaid separately authorized — not eliminated
- 504 plans, nursing care & mental health plans now billable
- CANS assessments qualify students without an IEP
- Public Health Package: any Medicaid student, no plan of care needed
- Screenings, SBIRT, med admin, provider consultations now covered
- New providers: MFTs, LICDCs, PAs, CNPs, CNS, supervised trainees
- OT/PT/SLP interventions now billable — not just evaluations
- Ohio updating MAC reimbursement calculation method
- Final details still being finalized by ODM
- Federal CMS deadline for State Plan Amendment submission
- Ohio SPA still working through approval process
- SPA outcome affects final reimbursement rates
- ODM open office hours: 3rd Wednesday, 12–1 p.m. monthly
July 1, 2025: Ohio MSP Gets a New Home (and New Rules)
The most significant administrative shift in recent memory took effect on July 1, 2025: day-to-day MSP operations transferred from the Ohio Department of Education and Workforce (DEW) to the Ohio Department of Medicaid (ODM).
This wasn’t just a paperwork change. It signaled a shift in how Ohio views school-based Medicaid, less as an education function and more as a health services program with corresponding accountability expectations.
Along with that transfer came two immediate requirements:
1. Every participating district must now appoint an MSP Coordinator.
This person serves as your district’s official point of contact with ODM, the go-to for receiving program updates, communications, and guidance. If your district hasn’t formally designated someone in this role, that’s step one.
2. RMTS got stricter and broader.
The Random Moment Time Study (RMTS), the survey system used to calculate how much of staff time is Medicaid-reimbursable, was updated in three ways:
- Contracted providers must now be included in RMTS (previously they often weren’t)
- Response time dropped from 5 business days to 2 (48 hours to respond to a moment)
- A 4th quarter was added covering July through September, meaning districts were previously leaving summer-adjacent activity on the table
The tighter response window is the one that catches districts off guard most often. Missing moments has a direct impact on your reimbursement rate. Make sure the right people know about the change and have the mobile access they need to respond quickly.
💡 Takeaway for school districts:
July 4, 2025: The Federal Wildcard
On Independence Day 2025, President Trump signed the One Big Beautiful Bill Act into law. For school districts, buried inside a sweeping piece of legislation was something worth paying close attention to: over $1 trillion in federal Medicaid cuts over the next decade, averaging roughly $100 billion per year.
Ohio is not insulated from this. Policy experts estimate Ohio alone could lose more than $5 billion in federal Medicaid funding over the next ten years. A $202 million rural health grant Ohio received in early 2026 helps at the margins, but by analysts’ own admission it doesn’t come close to offsetting the scale of reductions.
What does this mean for schools? Honestly, the full picture is still coming into focus. Federal Medicaid cuts don’t automatically eliminate MSP, since school-based Medicaid is separately authorized and administered. But the broader enrollment restrictions and coverage reductions in the law, including new eligibility restrictions for certain immigrant children, will reduce the pool of Medicaid-enrolled students in some districts. Fewer enrolled students means a smaller universe of billable services.
This is a situation worth watching closely. Districts with strong MSP billing programs and good data will be in a better position to advocate for themselves as the policy environment continues to shift.
January 1, 2026: The Big Expansion
This is the change with the most immediate upside for Ohio districts. Effective January 1, 2026, ODM updated Ohio Administrative Code 5160-35, and the scope of what schools can bill for got substantially broader.
Expanded Student Eligibility: Beyond the IEP
Historically, MSP reimbursement required services to be tied to an Individualized Education Program (IEP). That’s no longer the case. Under the new School Services Plan of Care framework, districts can now bill for Medicaid-enrolled students who have:
- A 504 Plan
- A nursing care plan
- A mental health treatment plan
- A Child and Adolescent Needs and Strengths (CANS) assessment
- Other qualifying health service plans
Many students receiving speech therapy, occupational therapy, behavioral health services, or nursing care through a 504 or health plan were previously invisible to MSP billing. They’re now billable, provided documentation requirements are met.
The new School Services Plan of Care is a standardized, time-bound template maintained by ODM. It covers demographics, signatures, and either an alternative documentation form or a Documentation of Medical Necessity Questionnaire. Review the current template on the ODM’s MSP webpage if you haven’t already.
💡 Takeaway for school districts:
The Public Health Package: Services for All Medicaid-Enrolled Students
One of the more underappreciated additions is what ODM is calling the Public Health Package. It’s a set of services that can now be reimbursed for any student enrolled in Medicaid, even without a plan of care, as long as medical necessity is documented:
- Physical, mental, and behavioral health screenings
- Administration of prescribed medications
- Provider consultations (including contacting prescribers about orders)
- Parent and provider consultations about a health condition or diagnosis
- CANS assessments (by a trained CANS Assessor, if not previously completed)
- Tobacco and vaping prevention and cessation services
- Screening, Brief Intervention, Referral, and Treatment (SBIRT) for substance misuse
If your nurses and counselors are doing these things (and they almost certainly are), there’s now a billing pathway that didn’t exist before.
More Service Types and Provider Roles
The January 2026 updates also expanded what can be billed and who can bill it:
- OT/PT: Interventions (not just evaluations) are now reimbursable, with additional CPT codes added
- Speech-Language Pathology: Interventions now covered, more CPT codes added
- Behavioral Health: New provider types including Licensed Marriage and Family Therapists (MFTs/IMFTs), Licensed Chemical Dependency Counselors (II, III, LICDCs), and CANS Assessors; trainees and assistants under supervision also now included
- Nursing: Physician Assistants (PAs), Certified Nurse Practitioners (CNPs), and Licensed Clinical Nurse Specialists (CNS) now qualify; preventive screenings, chronic disease management, and behavioral health nursing services added
If your district employs any of these provider types and they’re not yet included in your billing, it’s worth a closer look.
July 1, 2026: What’s Coming Next (Mark Your Calendar)
Two major changes are on the horizon for this summer:
1. MAC Reimbursement Changes. Ohio will update how Medicaid Administrative Claiming (MAC) reimbursement is calculated starting July 2026. The details are still being finalized, but districts should be talking with their billing vendors or internal MSP coordinators now to understand what’s coming.
2. CMS Compliance Deadline. July 1, 2026 is also the federal deadline by which states are expected to have submitted any necessary State Plan Amendments (SPAs) to bring school-based Medicaid programs into compliance with updated CMS guidance from 2023. Ohio’s SPA is still working through the approval process, and how that concludes will affect final reimbursement rates and the full rollout of expanded services.
💡 Takeaway for school districts:
What Districts Should Be Doing Right Now
Given everything above, here’s a practical checklist for where to focus your energy:
- Appoint (or confirm) your MSP Coordinator. If this hasn’t been formalized, do it now. ODM is actively routing communications through this role.
- Audit your RMTS participation. With the 2-day response window and contracted staff now included, your RMTS pool has likely changed. Make sure everyone who should be participating is enrolled and knows they have 48 hours, not 5 days, to respond.
- Review your student population for new billing opportunities. Pull a list of students with 504 plans, nursing care plans, or behavioral health plans who are Medicaid-enrolled. These students may now be billable under the School Services Plan of Care framework.
- Check your provider roster. Are any of the newly eligible provider types working in your district? MFTs, PAs, CNPs, LICDCs? If so, loop them into your billing workflow.
- Get familiar with the Public Health Package. Talk to your nurses and counselors about what they’re documenting. If they’re conducting screenings, SBIRT, or medication administration for Medicaid students, make sure that documentation supports billing.
- Stay close to the SPA approval process. ODM holds monthly open office hours on the third Wednesday of each month from 12 to 1 p.m. Subscribe to ODM’s MSP GovDelivery email list for updates. Questions can go to MedicaidSchoolPrograms@Medicaid.Ohio.Gov.
- Start planning for July 2026. Work with your billing vendor or internal team now to understand how MAC changes will affect your reimbursement calculations.
The Bottom Line
The last twelve months have brought the most significant changes to Ohio’s MSP in years. Some of them are genuinely positive, like broader eligibility, new services, and new provider types. Some require real attention, like the RMTS changes and federal funding uncertainty. And some are still unresolved, including the SPA approval and upcoming MAC recalculations.
Districts that stay engaged, keep documentation tight, and take advantage of the new service expansions will be in a stronger position than those waiting to see how things settle. MSP revenue supports the staff who support your students, and it’s worth the attention.
For official program guidance, visit the Ohio Medicaid School Program webpage or review the MSP Billing Guidance effective January 1, 2026.
💡 Recommended reading: 8 Best Practices That Can Increase Your Medicaid Funding
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