CMS Approves Illinois Proposal to Expand Access to Care for Kids in Schools

Apr 18, 2023

Today, the Department of Health and Human Services (HHS), through the Centers for Medicare & Medicaid Services (CMS), approved a state plan amendment (SPA) that will provide Illinois more Medicaid funding for eligible children receiving Medicaid-covered health care services in schools. This approval advances the expansion of school-based health services, a key priority for the Biden-Harris Administration to improve health care access, especially for youth mental health services. Today’s action is also part of ongoing efforts by HHS in support of President Biden’s call to address the nation’s mental health crisis, including its impact on children.

“Today we celebrate the historic action taken by Illinois to expand access to critical health care services in schools for eligible children,” said HHS Secretary Xavier Becerra. “The Biden-Harris Administration is committed to meeting children where they are to provide care that addresses the challenges our nation’s youth are facing, including mental health challenges. I am hopeful additional states will follow Illinois’ lead.”

“We’re thrilled to partner with states like Illinois to seize opportunities in Medicaid to expand access to health care in schools,” said CMS Administrator Chiquita Brooks-LaSure. “CMS encourages all states to consider adopting this flexibility. It just makes sense to deliver health care services and supports to children where they spend the majority of their time: in school.”

Illinois’ newly approved SPA allows schools to receive more Medicaid funding for covered services for all children with Medicaid, rather than only those children with an Individualized Education Program (IEP), which is a plan or program tailored for children with disabilities.

This SPA approval represents one of several steps CMS and HHS are taking to promote access to school-based health services and the availability of Medicaid-covered services, including mental health treatment in schools. Last year, Secretary Becerra and U.S. Department of Education Secretary Miguel Cardona issued two letters (available here and here) to states, encouraging them to leverage federal resources, especially Medicaid, to expand school-based health services for children. In August, the Centers for Medicaid and the Children’s Health Insurance Program (CHIP) Services released additional guidance outlining best practices for the delivery of health services to kids in schools.

Additionally, as part of its implementation of the Bipartisan Safer Communities Act, CMS expects to release a Comprehensive Guide to Medicaid Services and Administrative Claiming, launch a new school-based services Technical Assistance Center in partnership with the Department of Education, and release a notice of funding opportunity for $50 million in grants to states to strengthen school-based health services. 

The school setting provides a unique opportunity to deliver health care services to children and adolescents, especially those enrolled in Medicaid. Together, Medicaid and the Children’s Health Insurance Program (CHIP) cover over 41 million children, or more than 50% of all children in the country. School-based health services — which can include preventive care, behavioral health services, physical and occupational therapy, and disease management, among other Medicaid-covered services — are important resources for Medicaid-enrolled children and their families and have been shown to improve health and academic outcomes.

Illinois joins 11 other states that have already expanded Medicaid payment for school-based health care services under their state plans. These include: Arizona, California, Colorado, Connecticut, Georgia, Kentucky, Louisiana, Massachusetts, Michigan, Nevada, and North Carolina. CMS celebrates and supports all states in expanding school-based health care services to more children with Medicaid.

For more information on Illinois’ SPA, please visit For more information on state opportunities to expand access to school-based services in Medicaid, see CMS’ August 2022 informational bulletin.

New Counseling Opportunities

Beginning January 1st, 2023, LEA’s are able to bill for individual and group counseling provided by Credentialed School Counselors. California Education Code 49600 has been updated to include provisions for direct services, allowing the role of school counselors in mental and behavioral health. Specifically, it clarifies that school counselors are mental health professionals,

A recent California Association of School Counselors article by Loretta Whitson, Ed.D. discusses the changes and potential billing opportunities for LEA’s. Practi-Cal has also informed our clients of this new policy change and are working with our clients to identify potential service and billing opportunities. You can read the article here.

Using the new CDE Implementation requirements to improve Medi-Cal Billing

The forthcoming CDE implementation requirements provide an opportunity to improve Medi-Cal reimbursement for California LEA’s. The new CDE policy, requires LEA’s to document the minutes providing promised services to students in special education. While promised services may be delivered, they are not necessarily being documented. Practi-Cal tracks promised service delivery using algorithms that analyze special education data and models of delivery for each student. Practi-Cal also reports out service compliance data that allows LEA leaders, department leads, and service providers to drill down to identify missing services.

To improve Medi-Cal billing, Practi-Cal uses the same data and reports out services that have not been documented for Medi-Cal eligible students. While some students may not qualify for a variety of other reasons, until a service record is documented, your LEA will be in the dark on potential reimbursement. Practi-Cal also reports out the missing potential reimbursement amounts for services that have yet to be documented. LEA’s are finding that in some cases, they could double the size of their reimbursement program just on the amount of undocumented services.

How do program leaders monitor and track missing services and potential reimbursement? Program leaders should actively review their Program Health Dashboard in SpEdCare. This dashboard provides valuable tools to drill-down and identify actionable tasks to improve program results.

One of these tools is the Projected Reimbursement for Promised Services widget. This widget pulls in promised services (IEP and Non-IEP) in a variety of practices, where services have been promised to Medi-Cal eligible students, but not yet documented. Clicking on any bar in the graph will open a screen to allow leaders to drill-down and see exactly what Medi-Cal covered services are missing for each student.

Once services are recorded, a few may still be held for a variety of reasons, such as parent consent or a valid prescription or order. These held claims can be viewed on the Potential Reimbursement widget. Leaders can again drill-down, by clicking any portion of the chart and take action to fix or follow-up on compliance factors that are holding the claims. Once these compliance items are fixed, the claims will be released for adjudication and reimbursement.

Unwinding the Public Health Emergency (PHE) for LEAs

On October 13, the US Government extended the current Public Health Emergency (PHE) another 90 days.  This pushes the current federal expiration date to January 2023. During the past few State Workgroup meetings, DHCS shared information about unwinding the PHE and what that means for Medi-Cal beneficiaries.  There are currently two main effects ending the PHE will have on LEA’s and billing for school-based services. 

  • Continuous coverage will end for many Medi-Cal beneficiaries
  • The Federal Medical Assistance Percentage (FMAP) will go back to 50%

Let’s dive deeper into these two items.  As of March 1st, 2020, all Medi-Cal beneficiaries were given continuous coverage status through the end of the PHE.  This means that their Medi-Cal benefits were automatically renewed, and families did not need to qualify as normal.  Once the PHE ends, these Medi-Cal beneficiaries may have their benefits automatically terminated.  For these families to continue their benefits, they will need to either re-enroll or provide information to update their qualification status. Based on CMS policy, California has elected to end the PHE in February of 2023. 

Next, as an incentive and condition to provide continuous coverage, states were given a 6.2% increase in the FMAP. California’s normal FMAP is 50%, which means that Medicaid fee-for-service programs (like LEA BOP and SMAA) are eligible for 50% of the published rate for a direct and administrative service provided to a beneficiary.  As of March 1st, 2020, California’s FMAP was increased to 56.2%.  This means LEAs were reimbursed an additional 6.2% for eligible services. 

Over the course of the year following the end of the PHE, two actions will occur. The FMAP rate will return to 50%, reducing the amount LEAs receive for each eligible direct service.  Tying this with millions of potential beneficiaries losing Medi-Cal coverage, this may have a significant impact on LEA Billing Programs. 

But there is a plan.  CMS has developed an outreach campaign to assist Medicaid and CHIP beneficiaries in renewing.  This campaign is designed to reduce the gaps in coverage and ensure families and children receive needed care.  DHCS has also developed a plan in tandem with CMS and the success of this outreach campaign will hinge on communication. 

So how can LEA’s assist?  Begin providing outreach assistance now to students and families.  You do not need to know anything about a family’s insurance or financial situation to provide eligible outreach assistance.  The sooner families renew their benefits or update their information to qualify, the less chance there will be that they will have a gap in coverage. 

How is Practi-Cal assisting LEA’s?  Practi-Cal recognizes the effect of ending the PHE will have on students receiving health care services and how that affects education.  We also recognize the financial impact this will have on school-based billing programs.  For these reasons, we have registered to be DHCS Coverage Ambassadors, to assist with promoting outreach and raising awareness of the benefits of Medi-Cal coverage in education.   

Practi-Cal has also developed an electronic method for LEA’s to easily facilitate outreach campaigns directly from our software.  While this option is ready for our clients, it is currently on hold, as DHCS must first revise the Data Use Agreement (DUA), to include outreach, as an acceptable use of benefits information data. Practi-Cal focuses on being program compliant, and once the new DUA is submitted by LEA’s, you will be able to not only view beneficiary eligibility data (currently allowable and available), but further use this data to drive outreach campaigns at the click of a button.  Practi-Cal will provide materials and verbiage to make running your campaigns quick and easy.  You can target families with expired benefits or reach all families within your LEA.  Practi-Cal is also adding insurance application information to our Parent Portal, to assist with connecting families to Medi-Cal.

DHCS is still working on the new DUA, but we encourage you to reach out to DHCS to encourage them to approve and release the new DUA timely, as states are already working on outreach campaigns in preparation.  LEAs can reach program leadership at DHCS by emailing  Ask DHCS to please approve and release the new DUA as quickly as possible, so that you may assist with both state and national efforts.  If you do reach out to DHCS, we would love to know.  Please drop us a line at

If you would like more information about the unwinding of the PHE, our campaign features, or electronic outreach materials, you can reach us at: To learn more about Practi-Cal, visit our website at