Georgia Medicaid School-Based Services (2026): IEP, EPSDT, SBHCs

Georgia Medicaid pays for the health services a Medicaid-enrolled student receives at school. That includes the speech, occupational, and physical therapy written into a student's Individualized Education Program (IEP), Early and Periodic Screening, Diagnostic, and Treatment (EPSDT) checkups, and the primary care and counseling delivered inside a School-Based Health Center.

In This Guide

• How Georgia Medicaid pays for school-based services
• Does billing Medicaid affect my child's IEP?
• What changed in 2014 and 2023
• Which Georgia Medicaid school-based services are covered
• School-Based Health Centers and school mental health
• How the money is split: RMTS and administrative claiming
• How to navigate school-based services in Georgia
• Learn More

A note on audience: this guide covers Medicaid health services for school-age children, which sits outside Brevy's core focus on eldercare. We maintain it for Georgia families navigating a child's IEP and school health coverage.

How Georgia Medicaid pays for school-based services

Federal law lets Medicaid pay for health services included in a child's IEP or Individualized Family Service Plan (IFSP) under the Individuals with Disabilities Education Act. That authority originated in an amendment to that law enacted as part of the Medicare Catastrophic Coverage Act of 1988 and is now codified at Social Security Act Section 1903(c) (42 U.S.C. Section 1396b(c)), which provides that Medicaid payment is not barred for covered services furnished to a child with a disability because those services are in the child's IEP.1 In plain terms: when a Medicaid-enrolled student receives a covered, medically necessary service written into the IEP, the school district can bill Medicaid for it.

The IEP is the legally enforceable document that specifies services for a child with a disability. IDEA Part B covers school-age children ages 3 through 21; IDEA's early-intervention provisions cover infants and toddlers from birth through age 2, which in Georgia is the Babies Can't Wait program and is administered separately from school-based services. The IEP is reviewed at least annually, and the child is reevaluated for eligibility at least every three years.

Medicaid billing is a funding mechanism for the school district. It does not change the student's right to services. The district must deliver every service on the IEP as part of Free Appropriate Public Education (FAPE) under IDEA, whether or not Medicaid pays.

Does billing Medicaid affect my child's IEP?

No. This is the single most common worry Georgia families raise, and the rule is the opposite of what most parents fear. Under the IDEA Part B regulation at 34 CFR 300.154(d), a school district must get a parent's written consent before it bills Medicaid for IEP services for the first time, and that consent is voluntary. The district may not require a parent to enroll in Medicaid as a condition of the child receiving FAPE, may not charge the family an out-of-pocket cost such as a deductible or co-pay, and may not use the child's Medicaid if doing so would decrease available lifetime coverage or another insured benefit.2

The protection that matters most: a parent's refusal to consent to Medicaid billing does not relieve the school of its obligation to provide every required IEP service at no cost to the parents.2 Refusing billing cannot reduce, delay, or eliminate a child's therapy. Consent to bill is one decision; the child's right to services is a separate one that IDEA guarantees regardless.

What changed in 2014 and 2023

For decades, a federal "free care" policy generally barred Medicaid from paying for services a school offered free to all students, unless the service was part of a student's IEP or IFSP. In December 2014, CMS issued a State Medicaid Director letter (SMD #14-006, dated December 15, 2014) reversing that policy and making federal Medicaid payment available for covered services provided free of charge to the community, so long as all other Medicaid requirements are met.3

That reversal opened the door to a state option. A state may now elect to let school districts bill Medicaid for covered services delivered to any Medicaid-enrolled student, not only students who have an IEP or IFSP. As of October 2023, 25 states had expanded coverage beyond IEP/IFSP services.3

On May 18, 2023, CMS released "Delivering Service in School-Based Settings: A Comprehensive Guide to Medicaid Services and Administrative Claiming", its first comprehensive update to school-based Medicaid guidance since 2003. The guide was developed with the U.S. Department of Education to meet Section 11003 of the Bipartisan Safer Communities Act of 2022 (BSCA, P.L. 117-159), and it clarifies billing rules and adds new flexibilities.4 It is the live federal framework states are now aligning their school-based Medicaid programs to.

Which Georgia Medicaid school-based services are covered

The services a Georgia school district can bill to Medicaid when they are on a Medicaid-enrolled student's IEP include the following. The district must continue to provide each service regardless of whether Medicaid pays.

Beyond IEP services, EPSDT is the federal basis for routine school screening. The screening, diagnostic, and treatment benefit is Medicaid's comprehensive child health coverage for enrollees under age 21, defined at Social Security Act Section 1905(r) (42 U.S.C. Section 1396d(r)). It requires states to cover screening and the diagnostic services and treatment needed to correct or ameliorate conditions found through screening, whether or not those services are otherwise covered for adults under the state plan.6 In schools, that supports vision, hearing, developmental, and behavioral screening, and the follow-up care a screening reveals a child needs.

School-Based Health Centers and school mental health

A School-Based Health Center (SBHC) is a clinical practice located on school grounds that provides primary care and other services to students. SBHCs offer well-child and sick visits, immunizations, EPSDT screening, chronic-disease management such as asthma care, and behavioral health. Because of the 2014 free care reversal, an SBHC can bill Medicaid for covered services delivered to Medicaid-enrolled students, not only for IEP-specified care.3 SBHCs in Georgia are operated by federally qualified health centers, hospital systems, and local health departments, and they typically also bill private insurance and use sliding-scale fees for uninsured students.

Parental consent is required for SBHC care and for Medicaid billing. Some adolescent services follow Georgia minor-consent law for confidentiality, including pregnancy testing, contraception, and certain sexually transmitted infection and mental-health services.

Georgia's APEX (Adolescent and Pediatric eXcellence) program brings school mental health into schools by contracting community mental-health providers, including community service boards, to deliver therapy, crisis intervention, and tele-psychiatry for medication management. APEX is administered by the Georgia Department of Behavioral Health and Developmental Disabilities (DBHDD). For Medicaid-enrolled students, APEX behavioral-health services are billed to Medicaid. The Bipartisan Safer Communities Act of 2022 directed federal investment toward school mental health, and the 2023 CMS guide it required is the live framework for billing it.4

How the money is split: RMTS and administrative claiming

School-based Medicaid uses two funding mechanisms, both designed to avoid paying for the same service twice.

The Random Moment Time Study (RMTS) is a statistical sampling of school-staff time used to allocate costs across IDEA, Medicaid, and other funding streams. Staff who provide IEP-related services are sampled at random moments and each moment is categorized:

The sampled data is aggregated to determine the share of district expenditures eligible for Medicaid match. Medicaid Administrative Claiming is the separate mechanism for federal match on administrative activities that support the Medicaid program, such as helping families enroll, coordinating with CMOs, and scheduling Medicaid-billable IEP services.

Georgia administers Medicaid managed care through Georgia Families, which currently contracts three CMOs: Amerigroup Community Care, CareSource, and Peach State Health Plan.5 When a Georgia district bills Medicaid for a student's school services, the claim goes to that student's CMO.

How to navigate school-based services in Georgia

For a parent of a Medicaid-enrolled student, the practical steps are:

For a denied service or a dispute about IEP services, Georgia families can contact Disability Rights Georgia or Parent to Parent of Georgia for advocacy support. The Georgia Department of Community Health (DCH) is the single state Medicaid agency and administers the school-based services program with the Georgia Department of Education.

Putting it all together

Georgia Medicaid funds a wide range of health care inside schools: the IEP therapies a student with a disability is entitled to under IDEA, the EPSDT screening and follow-up care every Medicaid-enrolled child under 21 can receive, and the primary care and counseling delivered through School-Based Health Centers and the APEX program. The federal scaffolding is the Medicare Catastrophic Coverage Act of 1988 (now codified at 42 U.S.C. Section 1396b(c)), the EPSDT mandate, the December 2014 free care reversal, and the May 2023 CMS comprehensive guide.

The most important point for a Georgia family is also the most misunderstood: consenting to let the school bill Medicaid is a separate decision from your child's right to services. Under 34 CFR 300.154, refusing billing cannot reduce a single service on the IEP.2 The first step is to engage your child's school: confirm whether your child has or needs an IEP, whether the school has an SBHC, and whether APEX or tele-school-based services are available.

Learn More

Find personalized help navigating Georgia's school-based Medicaid services at brevy.com.

The information on Brevy.com is for educational purposes only and is not a substitute for professional legal, financial, or medical advice. Rules vary by state and program and change frequently. Always verify with the relevant agency or a qualified professional. Brevy is not a law firm, financial advisor, or healthcare provider.