Medicaid Payment for School-Based Services

Frequently Asked Questions: The Audiologist's and SLP's Role

Can an audiologist or speech-language pathologist provide and bill for school-based services?
I think my school should begin billing Medicaid for eligible children. What do I do?
School administrators have asked me to sign Medicaid claim forms for children receiving services from non-ASHA-certified providers. Can I do that?
What can I do if I believe a school district is engaged in fraud and abuse in its billing of Medicaid?
Can school-based ASHA-certified clinicians request a salary supplement for their participation in third-party billing?
How much Medicaid revenue is received for services I provide to Medicaid eligible students on my caseload?
How can I get Medicaid funds generated by SLPs or audiologists in my district back into SLP or audiology budget?

Can an audiologist or speech-language pathologist provide and bill for school-based services?

Yes. Both schools and individual practitioners within schools may be certified as Medicaid providers if they meet state provider qualifications.

School districts sign a provider agreement that enrolls it with the State's Medicaid program. The agreement establishes the rate of payment, the protocol for submission of bills, privacy issues and other details. States may establish liaisons between State Medicaid programs and educational agencies.

For individual practitioners, Federal Medicaid regulations state that a speech-language pathologist or audiologist is an individual who,

has a certificate of clinical competence from ASHA;
has completed the equivalent educational requirements and work experience necessary for the certificate; or
has completed the academic program and is acquiring supervised work experience to qualify for the certificate [42 CFR 440.110 (c)].

The speech-language pathologist and audiologist may be paid directly by Medicaid. An agreement between the speech-language pathologist/audiologist and the school district establishes a payment protocol.

I think my school should begin billing Medicaid for eligible children. What do I do?

First, make sure that you and your colleagues will be allowed to bill your services through Medicaid, then:

Talk with your colleagues. Find out from two or three of your colleagues if they also want what you do and if they would be willing to work with you to get it. In rural areas or small districts, your colleagues may be in neighboring school districts. Also, talk to a colleague who already bills through Medicaid. Gain support and learn from those who are already knowledgeable.

Do your research. Learn as much about Medicaid as you can. Talk to your regional Medicaid office or study your state's Medicaid plan. Study Medicaid regulations to determine what SLPs or audiologists can and cannot bill for. Determine if your services will generate enough money to make the program worthwhile for your school. Find out who the decision makers will be (the principal? teachers' union? etc.). Contact information for the 10 CMS regional offices that have direct oversight of state Medicaid programs can be found on the CMS Web site. Copies of state plans can be found on the CMS Web site or by requesting a hard copy of the document through the regional CMS office.

Prepare and present your case and be ready to answer tough questions! The most important thing to remember is that the more knowledgeable and prepared you are, the more you will understand what is best for you, your colleagues, and your students.

For more information on how to affect change and influence decision makers in your school, or to see how some of your colleagues have done so, visit the Schools Advocacy page.

School administrators have asked me to sign Medicaid claim forms for children receiving services from non-ASHA-certified providers. Can I do that?

Some guidance on supervision has been provided by the Centers for Medicare and Medicaid Services (CMS), but the issue still remains unclear. Federal Medicaid regulations state, "Services for individuals with speech, hearing, and language disorders" means diagnostic, screening, preventive, or corrective services provided by or under the direction of a speech pathologist or audiologist for which a patient is referred by a physician (Code of Federal Regulations, Title 42, section 440.110[c]).

Federal guidance is absent for determining how persons providing services "under the direction of" qualified personnel should be supervised. CMS offered an interpretation of "under the direction" within the context of school-based services in 1992, noting that the "direction" requirement means that a qualified (i.e., ASHA-certified or equivalent) speech-language pathologist must see the patient at least once, prescribe the type of care provided, and periodically review the need for continued services. CMS concluded that the speech pathologist accepts ultimate responsibility for care provided.

Schools and state Medicaid agencies may be establishing vague supervision policies that are not consistent with those of ASHA or CMS. For more information on ASHA's position read its Position Statement and Technical Report on Medicaid Guidance for Speech-Language Pathology Services: Addressing the "Under the Direction of" Rule. These guidelines can be used as a starting point for negotiations with the school district.

What can I do if I believe a school district is engaged in fraud and abuse in its billing of Medicaid?

ASHA is interested in hearing from you (e-mail reimbursement@asha.org) if you believe your school district is obtaining Medicaid payments by making false statements, misrepresentations, or is negligent in its efforts to bill Medicaid. Additionally, clinicians are obligated to work with their employers to effect change in the billing procedures. State speech-language-hearing associations may offer assistance, as well. For more information please go to the Center for Medicare and Medicaid Service's Medicaid Fraud & Abuse Web site.

Can school-based ASHA-certified clinicians request a salary supplement for their participation in third-party billing?

Yes. For example, clinicians in Minneapolis Public Schools were making little progress in their efforts to garner a salary increase until the school district started to bill Medicaid for speech-language pathology services. Because the state required ASHA CCCs (or equivalent) for third-party billing, but not for being a school-based SLP, Minneapolis clinicians used the opportunity to argue for a salary increase for holding voluntary national certification. ASHA CCCs had value as the district began collecting reimbursement to support students in special education. The school district stood to receive significant reimbursement by having ASHA-certified SLPs fully participate in third-party billing. As a result, the SLP's union and school district signed an agreement providing a salary increase of more than $1,500.