Looking for a clearer way to manage school-based Medicaid billing and receive reimbursement for the services you already provide? This guide walks you through the process.
School Medicaid billing is an ongoing process that helps schools recover part of the cost of health care and support services they provide to Medicaid-enrolled students. It covers two areas:
Area 1
Direct services
Health services delivered to students, such as therapy and nursing.
Area 2
Administrative claiming
Activities that support access to care, such as Medicaid outreach and care coordination.
School-based services are part of Medicaid and the Children’s Health Insurance Program (CHIP), which are jointly funded by the states and the federal government.
An Individualized education program (IEP) outlines the services, modifications, and accommodations a student needs to receive special education under the Individuals with Disabilities Education Act (IDEA). Students qualify under one of IDEA’s 13 disability categories, such as specific learning disabilities, speech or language impairments, autism, or other health impairments like ADHD.
How the rules changed
Before 2014
IEP services only
Federal “free care” policy meant most districts could only bill Medicaid for eligible services listed in a student’s IEP.
December 2014
The free care rule is withdrawn
The Centers for Medicare & Medicaid Services (CMS) issued guidance known as the “free care policy reversal.”
2023
CMS reaffirms it
CMS’s school-based services guide confirmed that states can cover services for Medicaid-enrolled students without an IEP.
Today
States keep expanding
More states are updating their Medicaid plans to cover more services for more students.
25+
states have expanded school Medicaid beyond the IEP
12+
more states have changes pending
Submitting Medicaid Claims for Students Without IEPs
Whether your district can bill for students without an IEP depends on your state’s Medicaid plan. Check with your state or contact our team to learn how this applies to your district.
Healthier students are better learners, and CMS notes that access to school-based health services improves both health and academic outcomes.
If your district is already providing the health-related servicesRelated Services Support services (such as speech therapy, occupational therapy, or transportation) that are required to assist a child with a disability in benefiting from their educational program. required to help close the achievement gap, taking advantage of school-based Medicaid claiming can help you recover some of the costs associated with those programs.
$8B+
in Medicaid funding supports school health services nationwide each year.
4 in 10
public school students are covered by Medicaid or CHIP.
Source: Georgetown University Center for Children and Families, March 2026
4th
Medicaid is the fourth-largest federal funding stream for K-12 public schools.
Public schools billing Medicaid follow the same basic cycle, even though each state sets its own rules:
Confirm eligibility and consent
Check that the student is enrolled in Medicaid and that you have parental consent on file.
Deliver the service
A qualified provider delivers a billable serviceBillable Service A health-related service provided to a Medicaid-eligible student that qualifies for reimbursement under Medicaid guidelines. Examples include therapy, nursing services, and certain assessments.Districts identify and submit these services for reimbursement through Medicaid billing software built for schools., as outlined in the student’s IEP or care plan.
Document it
Record the date, time, provider credentials, and session notes.
Submit the claim
Send it to your state Medicaid agency.
Track and resubmit
Follow payments and denials, and resubmit fixable claims within your state’s deadlines.
Speech Therapy
Physical Therapy
Occupational Therapy
Personal Care
Behavioral &
Mental Health
Administrative Activities
Transportation
Nursing & Physical Health
These are just some examples of the billable services your district may provide. And remember, when it comes to Medicaid billing in schools, often both the evaluations and the treatment are reimbursable. When in doubt, don’t miss out. Ask!
What’s Billable in my State?
The services you can bill for vary from state to state.
While the CMS sets federal policy for school-based Medicaid, each state decides how to implement it. Check with your state Medicaid agency and Department of Education for the specifics, and feel free to reach out to our team any time if you need additional guidance.
Once your district is submitting Medicaid claims, the next step is to look at how to optimize your reimbursements. You’re already providing students with many great health-related services, but are you recovering all of the costs you can?
Here are four ways to help optimize Medicaid reimbursements for your district:
As we’ve discussed, this changes from state to state and evolves over time. However, being unfamiliar with what you can bill for, and which students are eligible, might mean you’re leaving reimbursement dollars on the table.
Technology can be a game changer when it comes to optimizing reimbursements. Time-saving features can make it easier for providers to enter services, while reports and dashboards can highlight areas of opportunity for administrators and your Medicaid billing team.
States set filing deadlines of up to 12 months from the date of service, and many are shorter. Submitting claims promptly gives you and your Medicaid billing partner time to fix common Medicaid denial reasons and rebill within your state’s resubmission rules.
Under IDEA, districts need one-time written parental consent before billing Medicaid for a student’s IEP services, plus an annual notice to parents. Electronic signature tools can streamline Medicaid consent and enable more billing opportunities.
1. Prioritize compliance today
Put clear, written processes in place that show your district understands federal and state Medicaid rules. A billing partner with compliant software and hands-on support can act as an extension of your team, strengthening Medicaid compliance and reimbursement at the same time.
2. Document, document, document
Good documentation is the foundation of Medicaid audit readiness. Write down your policies and procedures, use systems that capture service data in an easy-to-report format, and keep records for your state’s required retention period. Without them, you may have to return reimbursements you’ve already received.
3. Conduct a self-audit
A self-audit is a district-led review of your Medicaid program. Pick a small sample of last month’s services and check that:
Most issues are data-entry errors that are quick to fix. Our Medicaid consulting team also helps districts run risk assessments.
School Medicaid billing rules differ from state to state. Here are three common differences to understand:
01
Eligible services and students
States that have adopted the free care policy reversal can submit claims for eligible services provided to any Medicaid-enrolled student, while others are limited to students with an IEP. Some states also cover services like transportation and nursing, while others do not.
02
Supervision and provider requirements
Know your state’s rules for both providers and supervisors. For some services, the provider delivering the service must hold specific credentials, while in other states a supervisor’s credentials are enough.
03
Group size limits and documentation
Some services can be delivered and billed as group sessions, but group billing limits and documentation requirements vary from state to state.
For your state’s rules, see our state-specific Medicaid billing guidance.
Rules and processes for school Medicaid change often, which can make reimbursement a moving target. The right Medicaid billing software and easy-to-use technology can act as an extension of your team, helping your district recover the costs of the services it provides. Look for:
Technical support plus consultative services, with ongoing training and support your staff can count on.
A system and partner that help validate compliance before claims are submitted, giving your team peace of mind.
Time-saving features, like saving and reusing notes or entering multiple sessions at once.
Integrations with an IEP platform or student information system (SIS) that eliminate double data entry.
About Go Solutions
Go Solutions is committed to empowering school districts across the US with innovative solutions that positively impact student success and their school communities.
Our Medicaid billing software and expert Medicaid billing team help ensure your district is optimizing reimbursement and can continue to provide exceptional experiences for all students.
Have any questions? Let’s talk.
