Making ‘Medicaid to Schools’ Work for Students and School Districts

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Most Granite Staters have heard about or benefitted from Medicaid, the federal program that provides health insurance to individuals and families with limited resources. Similarly, most have heard of the federal Individuals with Disabilities Education Act (IDEA), especially those with a school-aged child with special needs. The IDEA requires all school districts ensure that students with a disability receive the necessary services to receive an education.

One of the key intersections of these two laws is the Medicaid to Schools program. Under this program, school districts may seek reimbursement for health care services schools are required to provide under IDEA. In the past, schools could only claim reimbursement for services provided under an Individualized Education Plan (IEP). In 2017, Governor Chris Sununu signed landmark legislation that expanded the program to cover health services for all Medicaid eligible students with a written care plan, regardless of whether they had an IEP.  The program includes services such as behavioral health services, personal care, and rehabilitation therapy services such as physical therapy.  Schools that participate in the Medicaid to Schools program may seek federal reimbursement when those services are provided to students enrolled in Medicaid.

Schools throughout New Hampshire benefit from Medicaid reimbursement, using these funds to offset the salaries of professionals that deliver services on school grounds. While Medicaid only provides reimbursement for services provided to Medicaid enrolled students, all students benefit when healthcare professionals are in the school.

Last summer, the Centers for Medicare and Medicaid Services, the entity that oversees Medicaid, issued clarifying guidance about the Medicaid to Schools program. While the guidance encourages and provides information on how to expand services, it also made clear that Medicaid can only reimburse schools for services that were ordered and provided by individuals who are qualified to do so under Medicaid. One implication of the guidance is that schools may not seek reimbursement for services provided by certified professionals that are not also licensed by an applicable health-related licensing board. In New Hampshire, there are 15 different types of licensed professionals such as psychologists, occupational therapists, and clinical social workers.

In response to the clarifying guidance, the New Hampshire Department of Health and Human Services (DHHS) designed state rules to protect the Medicaid to Schools program and the students and families that depend on the services. Had DHHS not acted, Medicaid could seek recoupment from any school that billed for services provided by a non-Medicaid qualified provider, putting school budgets and the State at risk. The Department’s emergency rule and the current proposed rule do not attempt to narrow payments to schools for reimbursable activity. Rather, DHHS wants to make sure schools know what services are reimbursable. While schools continue to provide services to their students, these changes currently limit schools’ ability to bill for services performed by non-medically credentialed professionals, leading to fiscal challenges for schools.

In light of those challenges, Governor Sununu, State Senator Jay Kahn, and other leaders worked together to identify ways we can help students and school districts through these changes. One result of that collaboration is Senate Bill 684. SB 684 accomplishes two critical things: First, it ensures that DHHS has continued authority to create rules that maximize federal reimbursement for schools participating in Medicaid to Schools. Second, it provides a pathway for qualified professionals who are certified by the Department of Education (DOE) and currently providing medical services in public schools to get the licensing they need to be eligible for reimbursement by Medicaid for the services those professionals provide.

This bill compliments an Executive Order signed by Governor Sununu that fast tracks the licensing process for individuals who are providing services under the Medicaid to Schools Program. The Order directs all relevant health-related boards to prioritize applications for individuals providing services under the Medicaid to Schools program and to expedite the processing of these licenses. The NH Office of Professional Licensure and Certification and the health-related boards have committed to that process and have been exceptionally responsive to the needs of stakeholders.

Leaders across the state, including teachers, providers, legislators, and advocates, have joined forces to ensure that New Hampshire’s Medicaid to Schools program remains robust, students get the services they need to receive the best education possible, and schools are on solid fiscal ground. This collaboration has set the State on a path to build one of the best Medicaid to Schools programs in the country. We are committed to continuing this work as we work to serve the family and children in the State of New Hampshire.


Christine Brennan is Deputy Commissioner of the New Hampshire Department of Education.

Lisa English is the Director of Intergovernmental Affairs of the New Hampshire Department of Health and Human Services.

Henry D. Lipman, FACHE, is Medicaid Director of the New Hampshire Department of Health and Human Services.