The NASP Advocacy Roadmap
for States:
School-Based Medicaid
Services
A state level response resource to changes
in school-based psychological services for
Medicaid eligible students
NASP Advocacy Roadmap for
States: School-Based Medicaid
Services
• Set of resources designed to help state associations
plan their grassroots advocacy response to changes
in school-based psychological services to Medicaid
eligible students.
• State association leaders and members need to
actively monitor and respond to any changes in
school-based psychological services and
limitations placed upon these services provided
by school psychologists.
NASP Advocacy Roadmap for
States: School-Based Medicaid
Services
• Since Medicaid State Plans and
credentialing standards are prerogatives
of state governments, school psychology
leaders within states wishing to respond
to changes within their state should
become familiar with the content of the
Roadmap and begin working at the state
level to identify areas of need and
appropriate activities for advocacy.
Exhibit A: Overview of Schoolbased Medicaid Services
• This is a brief handout that summarizes
key issues related to Medicaid and recent
changes that have impacted the provision
of school-based psychological services to
Medicaid eligible students.
Key Issues
• What are School-based Medicaid
Services?
• Individual State Medicaid Plans
• EPSDT
• Medicaid qualified providers
• Medicaid guidelines on provider
qualifications
Exhibit B: Brief Summary of the
Federal Medicaid Statute
• Summary of the authorization statute for
school-based Medicaid services.
Exhibit C: Summary of the U.S.
Department of Health and Human Services
Office of Inspector General’s Medicaid
Audits
• The Department of Health and Human Services’ Office
of Inspector General (OIG) has engaged in numerous
audits of school-based Medicaid services.
• The stated objective of these audits is to “determine
whether local education agencies and cooperatives
appropriately furnished, documented, and billed
school-based services claimed for Federal Medicaid
reimbursement and whether states appropriately
claimed Federal funding for the services.”
• Only a small percentage of the audits analyzed services
provided by school psychologists, broad
recommendations regarding “provider qualifications”
have resulted from many of these audits.
Highlights of OIG Audits
• 21 State OIG audits were reviewed (CT,
FL, IL, IA, KS, ME, MD, MA, MN, NV,
NJ, NY, NC, OK, OR, RI, TX, UT, VT,
WA, WI), for a total of 42 audit reports.
• 4 audits (MA, NY, RI, TX) addressed, in
part, school-based counseling services.
The CMS Medicaid and School Health: A
Technical Assistance Guide (1997)
• In order for schools or school providers to participate
in the Medicaid program and receive Medicaid
reimbursement, they must meet the Medicaid provider
qualifications. It is not sufficient for a state to use
Department of Education provider qualifications for
reimbursement of Medicaid-covered school health
services
• Further, Medicaid regulations [42 CFR § 440.240]
require that provider qualifications be uniform and
standard. This means that states cannot have one set
of provider qualifications for school providers and
another set of provider qualifications for all other
providers. Schools should check with the state
Medicaid agency to determine specific state
requirements regarding provider qualifications for
participation in the Medicaid program
Of the 21 states that were audited by
the OIG :
• 15 states have a pathway for non-doctoral psychologists
to provide services outside the school setting (CT, FL,
IL, KS, ME, MD, MA, MN, NJ, NV, NC, OR, TX, VT,
WI),
• 1 state obtained a “letter of equivalency” from the state
attorney general’s office (OK),
• 5 states have no pathway for non-doctoral level
psychologists to practice outside of school (IA, NY, RI,
WA, UT).
• Of these 5 states, only NY and RI experienced
procedural changes for reimbursement of school-based
psychological services.
• Washington does not bill for counseling services
provided by school psychologists.
Exhibit D: State Attorney
Generals’ Opinions Related to
School Psychology
• Official opinions offered by the State
Attorneys General were reviewed for all 50
states. Relevant opinions related to
school psychologists are summarized in
this exhibit. These opinions may be
helpful in formulating a state advocacy
plan
Oklahoma Attorney General
• Scope of practice of a school
psychologist is substantially equivalent to
that of a licensed psychologist. Allows
for Medicaid reimbursement.
Exhibit E: State Responses to Changes in
Medicaid Reimbursement for School
Psychological Services
• A survey was conducted with state school
psychology associations’ executives,
NASP SPAN Coordinators, and NASP
State delegates to ascertain changes in
school-based Medicaid services. A total
of 33 responses from 28 states were
received. This exhibit contains
comments and feedback provided by
various states.
Highlights of Survey
• Several states do not bill Medicaid for psychological
services in the schools
• Changes in Medicaid reimbursement procedures
have had a direct impact upon delivery of school
psychology services and hiring of school
psychologists.
• Some states have developed positive strategies to
ensure continuation of services. In general, states
that have uniform and standard qualifications for
providers in the schools and providers in all other
settings are able to continue eligibility for
reimbursement of services.
Exhibit F: Checklist for State
Advocacy Planning
• Responding to changes in Medicaid
reimbursement procedures for school
psychological services requires careful
planning by state associations. This
document summarizes the major
advocacy activities that need to be
addressed in order to provide a
comprehensive and coordinated response.
1.
2.
3.
4.
5.
The Top 10 Essential Advocacy
Activities
Identify association leaders and develop a clear set of
procedures for monitoring and responding to changes in
Medicaid State Plan.
Conduct a needs assessment of the advocacy skills and
knowledge of leaders and members.
Conduct a “risk” assessment (Exhibit I) of how vulnerable
your state is to potential policies that would remove the
right of non-doctoral and non-licensed school
psychologists to be eligible to be reimbursed for services
provided to Medicaid eligible students in school settings.
Complete the NASP Advocacy Roadmap for States: School-
Based Medicaid Services, Profile of School Psychology
Credentialing and Psychologist Licensing (Exhibit F).
Respond to needs assessment, risk assessment, Profile of
State Credentialing, and other NASP Advocacy Roadmap
for States: School-Based Medicaid Services materials by
developing a State Action Plan (Exhibit H).
The Top 10 Essential Advocacy
Activities
6. Set up ongoing State Action Plan (Exhibit H) monitoring
and evaluation system.
7. Establish communication methods with state school
psychologists where regular updates are posted, questions
answered, and time sensitive action requests can be made.
8. Identify and reach out to key stakeholders, allies and allied
organizations.
9. Prepare information packets or an “issue kit” that can be
accessed easily and quickly.
10. Work with state administrators, psychology licensing
boards, state credentialing boards, and other public policy
agencies and personnel to work out agreements that
articulate why school psychologists are essential to the
mission and purpose of schools.
Exhibit G: Profile of School Psychology
Credentialing and Psychologist Licensing
Related to School-based Psychological
Services
• It is recommended that every state gather
information about the school psychology
credentialing and psychologist licensing
practices of their state.
• This Credentialing Profile will help states
identify key information, public policy makers,
and licensing and credentialing procedures so
that school psychologists in each state are
prepared to mount a grassroots advocacy
campaign in response to changes in
reimbursement procedures.
Exhibit H: Summary of School
Psychology Advocacy Materials
• This handout provides links to a variety
of advocacy materials developed to help
state associations fine-tune their message
regarding the critical importance of the
services provided by highly qualified nondoctoral school psychologists.
Exhibit I: State Advocacy Action
Plan Template
• This is a template to help state
associations create an effective advocacy
plan in response to changes in Medicaid
reimbursement for school psychological
services. This tool will assist states in
identifying specific goals, associated
activities, timelines, personnel
responsible, needed resources, and
anticipated outcomes.
Exhibit J: Risk and Asset
Assessment Questionnaire
• This document is designed to help state
associations determine the degree of risk
and their assets in responding to potential
changes in Medicaid reimbursement
procedures for school-based services.
Exhibit K: Summary of Critical
Resources for States
• This document provides a summary of
critical online links to general Medicaid
resources, related websites and allied
professional groups. It includes links to
state level resources and sample items
from states.
Exhibit L: Frequently Asked
Questions about Working with a
Lobbyist
• One strategy that states may use in
responding to changes in Medicaid
reimbursement procedures is to hire a
lobbyist to help in monitoring and
responding to unfriendly legislation or
regulations.
• This guide provides helpful tips on
working with a lobbyist.
Exhibit M: Assistance Available to
States
• This document summarizes resources,
materials, and leader and staff contacts
that NASP is able to provide state
associations in mounting a campaign to
defeat any unfriendly proposals emerging
from changes in Medicaid reimbursement
procedures.
Where do I go from here?
• Become familiar with resources in the
Roadmap.
• Help others within your state association
understand the resources of the
Roadmap.
• Assess the needs of your state.
• Develop an Action Plan based upon your
needs.
Exhibit N: Using the NASP
Advocacy Roadmap: SBMS PPT
• This exhibit is this PowerPoint
presentation….
For More Information…
Stacy Skalski, NASP Director of Public
Policy
skskalski@naspweb.org
Gordy Wrobel, GPR Committee
gordywrobel@covelodge.com
John Kelly, GPR Committee
jkellypsyc@aol.com