Wisconsin’s Department of Health Services (DHS) and Department of Public Instruction (DPI) are rolling out significant updates to Medicaid School-Based Services (SBS) that promise to reshape how special education services are delivered and reimbursed. These changes, driven by a state-initiated reversal of the Free Care Rule and new federal mandates from the Centers for Medicare & Medicaid Services (CMS), aim to expand access, streamline compliance, and ensure students receive the support they need. Here’s a deep dive into what’s coming and what it means for schools, providers, and families.
Expanded Access to Medicaid School-Based Services
One of the most transformative changes is the expansion of SBS eligibility. Previously, only students with Individualized Education Programs (IEPs) qualified for Medicaid-covered services in schools. Now, the program will include Medicaid-enrolled students without IEPs, encompassing those with 504 plans, Individual Health Plans, Behavior Intervention Plans, doctor’s orders, or other documentation establishing medical necessity. This broader eligibility opens doors for more students to access critical services, from speech therapy to mental health support.
The scope of covered services is also growing. New additions may include physician services, dental care, targeted case management, and expanded Early Periodic Screening, Diagnostic, and Treatment (EPSDT) services. To deliver these, Wisconsin is introducing new provider types, such as Board-Certified Behavior Analysts and Registered Behavior Technicians, with potential expansions into areas like Applied Behavior Analysis (ABA) therapy. A Medicaid plan of care will remain a prerequisite for most billable services, and documentation requirements will align with those for IEP students, ensuring consistency.
Here’s a quick rundown of what’s new:
- Now includes Medicaid-enrolled students without IEPs, covering 504 plans, Individual Health Plans, Behavior Intervention Plans, or doctor’s orders.
- Adds new services like physician, dental, targeted case management, and expanded EPSDT, with new provider types (e.g., Board Certified Behavior Analysts, Registered Behavior Technicians).
- Requires a Medicaid plan of care for most billable services, with same documentation as IEP students.
Click to view the full infographic on what’s changing in special education Medicaid services across Wisconsin.
Specialized Transportation: A Shift in Standards
Transportation for students with special needs is another area facing significant updates. CMS is tightening reimbursement criteria, limiting coverage to trips on physically modified vehicles—think wheelchair lifts, ramps, or special harnesses. The presence of an aide no longer qualifies a vehicle as “specialized,” which could impact schools’ budgets. For students whose IEPs include transportation but don’t require modified vehicles, schools may need to tap alternative funding sources, like IDEA grants, to meet Free and Appropriate Public Education (FAPE) obligations. This shift underscores the need for careful planning to ensure compliance and student access.
To sum it up, major updates include:
- Reimbursement limited to physically modified vehicles (e.g., wheelchair lifts, ramps, special harnesses).
- Aides alone no longer qualify vehicles as specialized; schools may need alternative funding (e.g., IDEA) to meet FAPE requirements.
💡 Takeaway for school districts:
Having the right tools and preparation is key. School districts should equip themselves now to maximize Medicaid billing opportunities under Wisconsin’s updated SBS program.
Federal Compliance: NPIs and Time Studies
To align with CMS guidance, Wisconsin is implementing stricter compliance measures. A Type 1 National Provider Identifier (NPI) will now be required on claims involving prescriptions, referrals, or orders. DHS and DPI are exploring ways to roll out this requirement smoothly, potentially allowing flexibility in how NPIs are used across providers. Meanwhile, the Random Moment Time Study process is getting an overhaul. Schools will face a “zero notification” policy, meaning no advance warning before a study moment, and the response window is shrinking from five school days to two. These changes aim to improve accuracy and accountability in how Medicaid funds are allocated.
- National Provider Identifier (NPI) mandatory for claims with prescriptions, referrals, or orders. The waiver will no longer be valid.
- Random Moment Time Study changes: zero notification policy and two-school-day response window.
What’s Next for Wisconsin Schools?
DHS is actively collaborating with CMS and the national technical assistance center to refine these changes before submitting the State Plan Amendment (SPA). To prepare providers, DHS is partnering with Public Consulting Group (PCG) to develop comprehensive training. Meanwhile, DPI and DHS are eager to hear from stakeholders. From now until May 31, 2025, they’re soliciting feedback to shape the SBS expansion, ensuring it meets the needs of students, families, and educators.
💡 Recommended reading: Factors Affecting Students’ Medicaid Eligibility for School-Based Services
💡 Recommended reading: A Guide to State Reporting in Wisconsin
Final Thoughts
These changes reflect Wisconsin’s commitment to equitable access to special education services while navigating complex federal requirements. By expanding SBS eligibility and services, more students will benefit from tailored support. However, the transition won’t be without challenges—schools will need to adapt to new transportation rules, comply with tighter CMS mandates, and prepare for increased documentation demands. The feedback period offers a critical opportunity for educators, providers, and families to influence how these changes unfold.
As Wisconsin moves forward, staying informed and engaged will be key. Schools should begin assessing their transportation fleets, training staff on NPI requirements, and preparing for the updated time study process. For families, these changes mean more opportunities for their children to access vital services, regardless of IEP status. Together, these efforts will help ensure Wisconsin’s special education system remains robust, inclusive, and responsive to student needs.
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