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OK SPA 25-0005 & APA WF# 25-04 School-Based Services Expansion

The Oklahoma Health Care Authority (OHCA), in collaboration with the Oklahoma State Department of Education (OSDE), seek to enhance school-based services across the State. Policy changes will allow for an expansion of school-based services for all Medicaid eligible students that meet the criteria for medical necessity. These services are currently only reimbursable for students with an Individualized Education Plan (IEP) or an Individualized Family Service Plan (IFSP). Policy revisions will establish new school-based services, such as specialized transportation, and enhance existing school-based services, specifically around nursing, behavioral health, and nutrition services.

Please view the draft circulation document APA WF #25-04 and draft SPA 25-0005

Interested parties may submit feedback via the comment box.

Circulation Date: 12/27/2024

Tribal Consultation: 01/07/2025

Comment Due Date: 1/11/2025

Effective Date: 7/1/2025; Contingent Upon CMS & Gubernatorial Approval

Submit a Comment

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After you submit your comment, you should be re-directed to a confirmation page. If you are not, please submit your comment through e-mail to federal.authorities@okhca.org.

Please note that all comments must be reviewed and approved prior to posting. Approved comments will be posted Monday through Friday between the hours of 7:30 a.m. – 4 p.m. Any comments received after 4 p.m. will be posted on the following business day.


Comments

Allyson:

Suggested edit to APA WF# 25-04:

Per the Individuals with Disabilities Education Act (IDEA) 20 U.S.C. 1401(2), "The term "assistive technology service" means any service that directly assists a child with a disability in the selection, acquisition, or use of an assistive technology device."

In section 317:30-5-1023. Coverage by category, (2)F, the definition includes assisting with selection and use and should include mention of "acquisition" of assistive technology.

OHCA Response:

Thank you for you feedback. 


Brenda:

Please consider expanding this service to all students. There are many students with social-emotional needs who are not on an IEP. Our community services are limited, and many parents rely on the school to address these growing needs. Thank you

OHCA Response:

Thank you for you feedback. 


Wyanema:

I am excited that it could include students who are not on an IEP. We have several it would definitely benefit. We use the program now and it has helped us to recoup some of the money we spend on therapy services. Well worth the time to use the Medicaid program.

OHCA Response:

Thank you for you feedback. 


Mandy:

This is a fantastic opportunity for our students. I hope there is plenty of personnel to support the schools in getting their systems set up and running correctly.

OHCA Response:

Thank you for you feedback. 


Misti:

By broadening the scope of school-based services to students not on an IEP, this would enhance individual student support but also working towards building a healthier future for our communities. This would allow schools to provide more resources for the student success.  This collaborative effort is a vital step in ensuring that every student has the opportunity to thrive both in and out of the classroom.

OHCA Response:

Thank you for you feedback. 


Jennifer:

It is my belief that expanding the funding benefits would greatly benefit Oklahoma Schools and our students.  CREOKS Counselors are embedded in our district.  Two Counselors, two BHAs, and two Case Managers are housed, here at school, in order to provide services for our students each day.

OHCA Response:

Thank you for you feedback. 


Carla:

The Oklahoma Health Care Authority (OHCA), along with the partnership with the Oklahoma State Department of Education (OSDE), has introduced a State Plan Amendment (SPA) aimed at expanding school-based Medicaid reimbursement beyond Individualized Education Programs (IEPs). This expansion will allow schools to receive Medicaid funding for a wider range of health services provided to all eligible students, not just those with IEPs.

I strongly support this for the students and for the financial benefits to school districts that are already providing these services.

OHCA Response:

Thank you for you feedback. 


Natalie:

As a school based SLP in a title one school, my district would greatly benefit from an expansion of Medicaid services outside an IEP. To the students that remain at grade level but would greatly benefit from therapy services such as OT and PT that could be provided by the district as well as mental health services. Some parents lack transportation or have lack of knowledge of what their child needs, where this expansion can help bridge some of those gaps to better serve the children of Oklahoma.

OHCA Response:

Thank you for you feedback. 


Tracy:

I fully support the enhancement of school-based services.  Our school services students in all areas mentioned, specialized transportation, nursing, behavioral health, and nutrition services.  These additional services would greatly assist with all that schools encounter.  We appreciate the support OHCA and OSDE are providing to public schools in these important areas.  This expansion is greatly needed and appreciated. 

OHCA Response:

Thank you for you feedback. 


Alicia:

Expansion of school-based Medicaid reimbursement beyond Individualized Education Plans (IEPs) will allow schools to provide services to all eligible students, not just those with IEPs. By broadening access to these vital resources, Epic Charter Schools (and all participating public schools) will be better equipped to address students' mental health, physical health, and other critical needs, ensuring a healthier and more supportive learning environment for all. This change has the potential to significantly improve student outcomes and reduce barriers to care.

OHCA Response:

Thank you for you feedback. 


Kyle:

The expansion of Medicaid to cover students for services outside of an IEP can be crucial to support the needs of the students.  Too often services are limited for our students due to limited resources that are available.

OHCA Response:

Thank you for you feedback. 


Jeri:

I am in favor in enhancing school-based services across the state. 

OHCA Response:

Thank you for you feedback. 


Ashley:

I am writing to express my strong support for the proposed State Plan Amendment (SPA) by the Oklahoma Health Care Authority (OHCA) and the Oklahoma State Department of Education (OSDE) to expand Medicaid reimbursement for school-based health services beyond Individualized Education Programs (IEPs). This initiative has the potential to transform the landscape of student health and well-being in our schools. By broadening access to Medicaid funding for health services provided to all eligible students, schools will be better equipped to address critical needs such as mental health, physical health, and preventative care. These services are vital to ensuring that all students, regardless of their educational status, have access to the support they need to thrive both academically and personally. For many families, schools are the most accessible point of contact for healthcare services. Expanding Medicaid reimbursement will not only improve the quality and availability of care for students but will also reduce barriers such as transportation, cost, and time that often prevent families from seeking necessary healthcare. This change will ensure that students receive timely interventions, which can have long-term positive impacts on their academic success and overall well-being. Furthermore, this amendment would alleviate some of the financial burdens on schools, enabling them to reinvest in other critical resources to support student learning. With access to expanded Medicaid funding, schools can hire more counselors, nurses, and other healthcare professionals who are essential to addressing the growing health needs of our students. The proposed expansion is a meaningful step toward creating equitable access to healthcare for all children in Oklahoma. I urge the OHCA to move forward with this amendment and work to implement it as soon as possible. By investing in the health of our students today, we are paving the way for a healthier, more successful generation tomorrow. Thank you for considering this critical initiative.

OHCA Response:

Thank you for you feedback. 


Lisa:

I strongly support the proposed policy changes by the Oklahoma Health Care Authority (OHCA) and the Oklahoma State Department of Education (OSDE) to expand school-based services for all Medicaid-eligible students who meet the criteria for medical necessity. By broadening access beyond students with IEPs and IFSPs, this initiative will address critical health, behavioral, and nutritional needs more equitably across our student population. The inclusion of specialized transportation and enhancements to nursing and behavioral health services is a forward-thinking approach that will positively impact student well-being, academic engagement, and long-term outcomes. Investing in these comprehensive supports is essential for creating a more inclusive and healthier learning environment for all children in Oklahoma.

OHCA Response:

Thank you for you feedback. 


Cathy:

I am writing in support of the initiative to expand school-based Medicaid reimbursement. Broadening access to resources will allow schools to be better equipped to address the ever-increasing needs of the students.

OHCA Response:

Thank you for you feedback. 


Sheli:

I am pleased to offer my support for the forthcoming policy changes announced by the Oklahoma Health Care Authority and the Oklahoma State Department of Education. The expansion of school-based services to all Medicaid-eligible students who meet medical necessity criteria is a significant advancement in our efforts to provide comprehensive support to our students. Currently, these essential services are limited to those with an Individualized Education Plan (IEP) or an Individualized Family Service Plan (IFSP). The proposed revisions, which include new offerings such as specialized transportation and enhancements to nursing, behavioral health, and nutrition services, will enable us to better address the diverse needs of our student population. This initiative underscores a critical commitment to student well-being and ensures that more children have access to the support they need to thrive both academically and personally. It is a reflection of our shared vision to remove barriers and create an inclusive environment where every child has the opportunity to succeed. Thank you to all those involved in making this vision a reality and for investing in the future of our children.

OHCA Response:

Thank you for you feedback. 


Monica:

We currently utilize school-based Medicaid services for our students in special education. As a district, it has helped us tremendously to be able to recoup some of the funds spent on services and put it right back into funds spent on those services. It would also be extremely beneficial for us to do so for our student population that is not on an IEP who is receiving mental health services in our district. We have two full-time LPCs on staff who serve as crisis counselors and one that we contract with part-time. All three provide on-the-spot crisis counseling and ongoing counseling services during the school day. Being able to bill for these services would help us offset the cost of contracting for additional help. 


Rachel:

This seems like a phenomenal step in the right direction to providing services for our students in Oklahoma. 


Last Modified on Jan 13, 2025