CMS Releases New State Grants for Medicaid and CHIP School-Based Services

Health Highlights

On January 24, CMS released a grants notice outlined in State Grants for the Implementation, Enhancement, and Expansion of Medicaid and CHIP School-Based Services (SBS). These grants were authorized through the 2022 Bipartisan Safer Communities Act (BSCA), Section 11003 (b). The BSCA also directed CMS to publish guidance on SBS, which was published in May of 2023, and to establish a technical assistance center.

CMS is asking, though not requiring, states to submit letters of intent by February 23, 2024. Applications are due March 25, 2024. State Medicaid Agencies must demonstrate partnership with State Education Authorities. The grants are essentially designed to be planning grants that will lead to a minimum two-year post-grant sustainability plan involving submittal of a SPA and any other relevant documents, such as a cost allocation plan, as needed.

All states are eligible for the funding opportunity, regardless of where they are in terms of expansion of their Medicaid-covered school-based services. CMS intends to award 20 states up to $2.5 million each over three years. The funds can be used for:

  • Implementing SBS for states that have not expanded coverage and billing of Medicaid and the Children’s Health Insurance Program (CHIP) services provided in schools beyond billing for services in a student’s individualized education plan (IEP). 
    • Example projects: According to Healthy Students, Promising Futures, as of October 2023, 25 states have not expanded school-based services in their State Plans. While this does not mean these states do not have any services in schools, for all of these states there is an opportunity to consider broadly what services should be offered by schools for children covered by Medicaid and CHIP.  For example, schools could consider offering behavioral health services to the student body, including screening, psychoeducation and therapy.
  • Expanding SBS in schools for states that have expanded the coverage and billing of Medicaid or CHIP services provided in schools beyond billing for services in a student’s IEP.
    • Example projects: Some states have worked with providers who offer vision or dental services in schools. Providers, such as Vision to Learn, can offer these services—even in places where there is no School-Based Health Center using mobile vans.
  • Enhancing SBS for states that have expanded services in schools by treating them as a setting wherein any Medicaid- or CHIP-participating provider can provide any Medicaid- or CHIP-covered service to any Medicaid- or CHIP-enrolled student in a school.
    • Example projects: Early childhood is one area in which SBS enhancement may have long-term payoffs. Some early childhood programs are operated by local education agencies, who could choose to provide Medicaid services to this population. Mental health consultation, a best practice in early childhood settings, can be covered by Medicaid and CHIP.

Manatt published a summary document of CMS’s May 2023 guidance that gives more information about what SBS can be covered in schools as well as the steps for establishing a Medicaid and CHIP SBS benefit. In this guidance, we noted that, there is no distinct Medicaid State Plan benefit called “school health services” or “school-based services”; nearly all Medicaid-covered services can be provided by or in schools, including but not limited to the following:

  • Vision and dental services
  • Preventive services for children, including immunizations and other physicians’ services
  • Occupational, physical and speech therapy
  • Individual therapy provided by a therapist hired by the school or through a contract
  • Targeted prevention programs for children at risk of developing a SUD
  • Full health care services for children and their families through an adjunct school-based health center
  • Navigation support in accessing Medicaid services
  • Consultative services provided in early childhood classrooms
  • Naloxone and naloxone training
  • Health education programs

Manatt also held a webinar on January 17, 2023 with additional information about services that can be provided in schools. Click here to view the free webinar on demand and download a free copy of the presentation. For questions or assistance, please contact Zoe Barnard at, Jocelyn Guyer at or Carley Clemons at



pursuant to New York DR 2-101(f)

© 2024 Manatt, Phelps & Phillips, LLP.

All rights reserved