Georgia Medicaid School-Based Services (2026): IEP, Free Care Reversal, SBHCs

By Brevy Care Team · Last verified May 12, 2026

Inside Georgia's public schools, Medicaid is doing more work than most parents realize. Speech-language therapy delivered through a kindergartener's Individualized Education Program is billed to Medicaid. Occupational therapy that helps a third-grader with autism learn to grip a pencil is billed to Medicaid. Tele-psychiatry that connects a rural high school to a child psychiatrist at a distant academic medical center is billed to Medicaid. Primary care delivered by the nurse practitioner inside the School-Based Health Center down the hall from the school office is billed to Medicaid. Behavioral health counseling through the Georgia APEX program is billed to Medicaid. School nursing services for a student with insulin-dependent diabetes are billed to Medicaid. Transportation when a student's Individualized Education Program requires specialized vehicle access is billed to Medicaid.

For decades before December 2014, the federal Free Care Rule limited Medicaid's role in schools to services delivered specifically on an Individualized Education Program under the Individuals with Disabilities Education Act (IDEA). The Free Care Rule was a Centers for Medicare and Medicaid Services interpretation that prohibited Medicaid payment for services that were also provided free to the general public. Because schools provide many services free to all students, the Free Care Rule constrained Medicaid's role in schools to IDEA-specific services. In December 2014, CMS issued a State Medicaid Director Letter reversing this interpretation. The Free Care Reversal opened the door to Medicaid payment for school-based primary care, school-based mental health, and other services regardless of whether they were also available free to non-Medicaid students. Combined with the Bipartisan Safer Communities Act of 2022 that funded a major federal investment in school mental health, the policy landscape now supports robust Medicaid billing across school-based service categories.

This guide explains the federal authorities that govern school-based Medicaid services (the Medicare Catastrophic Coverage Act of 1988, IDEA Part B, EPSDT, the 2014 Free Care Reversal State Medicaid Director Letter, the Bipartisan Safer Communities Act of 2022, HRSA School-Based Health Center funding, Section 504 of the Rehabilitation Act, and FERPA), the Georgia statutory framework (the Georgia special-education statute, the Georgia Medicaid State Plan, the Interagency Agreement between the Department of Community Health and the Georgia Department of Education, and the DCH Medicaid School-Based Services Provider Manual), the Random Moment Time Study cost-reconciliation methodology that allocates costs between IDEA and Medicaid funding streams, the Medicaid Administrative Claiming mechanism, the network of school districts that implement the program, the substantial network of School-Based Health Centers operating inside Georgia schools, the Georgia APEX school mental health program, tele-school-based services, parental consent requirements for Medicaid billing (separate from IDEA consent), and the Care Management Organizations that administer Medicaid managed care benefits. Six worked examples illustrate how the framework operates for real Georgia students. A frequently asked questions section addresses the most common questions families ask. A contact directory provides the phone numbers needed to navigate the system.

The federal framework

How Medicaid pays for IDEA services

The federal authority for Medicaid payment of services delivered through Individualized Education Programs traces to the Medicare Catastrophic Coverage Act of 1988. Before 1988, federal Medicaid policy was ambiguous about whether services delivered to children with disabilities through IDEA (then called the Education for All Handicapped Children Act of 1975) qualified for federal Medicaid match. The 1988 statute clarified that IDEA-related services delivered to Medicaid-eligible children with disabilities are reimbursable through Medicaid, and the federal match rate is established under the Social Security Act.

The Individuals with Disabilities Education Act, last reauthorized in 2004, guarantees Free Appropriate Public Education (FAPE) to children with disabilities ages 3 through 21. IDEA Part B covers school-age children (3-21). IDEA Part C covers infants and toddlers ages 0-3 in early intervention; in Georgia, this is the Babies Can't Wait program, administered separately from school-based services. The Individualized Education Program (IEP) is the legally enforceable document that specifies services for a child with disabilities. The IEP team includes the parent, regular education teacher, special education teacher, local education agency (LEA) representative, evaluator, and the child when appropriate. The IEP is reviewed annually and the child is reevaluated for eligibility every three years.

The services billable to Medicaid when included on an IEP include speech-language pathology, occupational therapy, physical therapy, audiology, vision services, behavioral health, school nursing for chronic medical conditions, and transportation when specialized transportation is required due to the disability. The IDEA legal standard of FAPE means the school district must provide the services on the IEP regardless of whether Medicaid pays. Medicaid billing is a funding mechanism for the district; it does not affect the student's right to services.

The Free Care Rule and its 2014 reversal

For decades before 2014, CMS interpreted federal Medicaid rules to prohibit payment for services that were also provided free to the general public. This interpretation, known as the "Free Care Rule," constrained Medicaid's role in schools. Schools provide many services free to all students regardless of insurance status: nursing, counseling, vision and hearing screening, basic first aid. Under the Free Care Rule, these services were not Medicaid-billable even for Medicaid-enrolled students, because they were also provided free to non-Medicaid students.

In December 2014, CMS issued a State Medicaid Director Letter reversing this interpretation. The letter clarified that Medicaid can pay for school-based services regardless of whether they are also available free to non-Medicaid students. The reversal opened the door to Medicaid payment for primary care in School-Based Health Centers, school-based mental health, and other services beyond IDEA-specific IEP services. Cost-allocation rules still apply: Medicaid cannot pay for the same service twice (no double-counting with IDEA federal funding), and parental consent is required for Medicaid billing.

The Free Care Reversal has been one of the most consequential federal Medicaid policy changes for schools in the past quarter century. It expanded the financial base supporting school-based health services and enabled the growth of School-Based Health Centers, tele-school-based services, and integrated school mental health programs.

EPSDT and school-based screening

The Early and Periodic Screening, Diagnostic, and Treatment benefit is the comprehensive Medicaid children's benefit. EPSDT requires states to cover screening (vision, hearing, dental, developmental, medical), diagnosis, and treatment for any condition discovered through screening, regardless of whether the service is covered in the State Plan for adults. EPSDT is the federal basis for school-based screening programs in Georgia and across states. School nurses conduct vision and hearing screenings; behavioral health professionals conduct depression and anxiety screenings; primary care providers in School-Based Health Centers conduct comprehensive well-child visits.

The Bipartisan Safer Communities Act of 2022

The Bipartisan Safer Communities Act was signed in 2022 following the Uvalde school shooting and other tragedies. BSCA provided a major federal investment for school mental health expansion, including funding for school-based mental health professionals, training programs, and intervention services. BSCA also expanded Medicaid coverage of mental health services in schools by clarifying federal flexibility and supporting state implementation.

For Georgia, BSCA accelerated the expansion of the Georgia APEX program (described below), funded tele-school-based mental health, and supported workforce development for school counselors and clinical social workers.

HRSA School-Based Health Center funding

The Health Resources and Services Administration provides grants for School-Based Health Centers under the Affordable Care Act and ongoing appropriations. HRSA grants support construction, expansion, and operating costs of SBHCs. Georgia operates a substantial network of SBHCs, many partnered with federally qualified health centers, hospital systems (Children's Healthcare of Atlanta, Emory Healthcare, Augusta University Health, Memorial Health Savannah, Northeast Georgia Health System), and local health departments. The Georgia Association for Primary Health Care coordinates SBHC development across the state.

Section 504 and the ADA

Section 504 of the Rehabilitation Act of 1973 prohibits disability discrimination by federally funded entities, including schools. Section 504 plans are accommodation plans (extended time on tests, breaks, accessible facilities, modified assignments) for students who do not qualify for an IEP but need accommodations for a disability. Section 504 services generally are not Medicaid-billable in the same way as IEP services, because they are accommodations rather than direct services.

The Americans with Disabilities Act of 1990, Title II, prohibits disability discrimination by public entities including public schools. ADA Title II reinforces Section 504 and IDEA obligations.

FERPA and HIPAA

The Family Educational Rights and Privacy Act governs student record privacy. FERPA covers education records maintained by schools. The Health Insurance Portability and Accountability Act covers protected health information held by covered entities. FERPA and HIPAA interact at the school-Medicaid boundary: a student's IEP is an education record under FERPA, but a billing claim submitted to Medicaid by a school nurse may also generate health records under HIPAA. Schools and Medicaid agencies coordinate to ensure both privacy frameworks are respected.

Other federal frameworks

The Every Student Succeeds Act of 2015 is the current federal K-12 education law, replacing No Child Left Behind. ESSA establishes accountability frameworks for student achievement and provides funding for low-income schools through Title I.

The McKinney-Vento Homeless Assistance Act establishes rights for homeless students, including school enrollment continuity, transportation to the school of origin, and access to services. Homeless students retain IDEA and Medicaid rights regardless of housing status.

IDEA Part C (ages 0-3) operates in Georgia as the Babies Can't Wait program, administered by DPH. Babies Can't Wait provides early intervention services for infants and toddlers with developmental delays or disabilities, separate from the school-based IDEA Part B framework.

Georgia's framework

State statutory authority

Georgia's special education statute implements IDEA Part B for Georgia's county and city school districts and sets IEP requirements under Georgia law. The Georgia Medicaid State Plan provides the statutory authority for Medicaid-funded school-based services.

The Georgia Department of Education (GADOE) administers IDEA Part B through the Special Education Services division. The Department of Community Health (DCH) is the single state Medicaid agency. The two agencies operate under an Interagency Agreement that defines responsibilities for school-based Medicaid services.

DCH Medicaid School-Based Services Provider Manual

DCH publishes the Medicaid School-Based Services Provider Manual, which sets the rules for school district billing of Medicaid for IDEA services and SBS-related services beyond IDEA. The manual covers billable services, documentation requirements, billing procedures, cost reconciliation through Random Moment Time Study, and reporting.

Georgia's school districts

Georgia's county and city school districts implement IDEA Part B and the school-based Medicaid program. The largest districts include Gwinnett County, Cobb County, DeKalb County, Fulton County, and Atlanta Public Schools. Rural districts in south and middle Georgia often have smaller enrollments and varying capacity for school-based Medicaid billing administration.

District maturity in SBS programs varies. Large urban and suburban districts typically have established Medicaid billing departments, contracts with billing vendors, and robust RMTS participation. Smaller rural districts may rely on regional educational service agencies (RESAs) for billing support or may not bill Medicaid at all for IDEA services, foregoing federal match revenue that could support program expansion.

Random Moment Time Study methodology

The Random Moment Time Study is a quarterly statistical sampling of school staff time used to allocate costs between IDEA, Medicaid, and other funding streams. School staff who provide IDEA-related services (special education teachers, related services personnel, paraprofessionals, school nurses, counselors) are sampled at random moments during the school year. Each sampled moment is categorized into:

• Direct service to Medicaid-enrolled students with IEPs (potentially Medicaid-billable)
• Direct service to non-Medicaid students with IEPs (not Medicaid-billable but counts toward IDEA cost)
• Administrative activities that support the Medicaid program (potentially eligible for Medicaid Administrative Claiming)
• General education or other activities (not Medicaid-related)

The sampled data is aggregated and used to allocate the school district's total expenditures into Medicaid-eligible and non-Medicaid-eligible categories. Medicaid reimburses at the federal medical assistance percentage (FMAP); consult the current CMS FMAP table for Georgia's effective rate. The Random Moment Time Study Committee oversees methodology and ensures statistical validity.

Medicaid Administrative Claiming

Medicaid Administrative Claiming (MAC) is a separate mechanism for federal Medicaid match on administrative activities that support the Medicaid program (outreach, eligibility determination assistance, care coordination, transportation arrangement, interagency coordination). Schools can claim MAC for IDEA-related administrative activities such as scheduling Medicaid-billable IEP services, coordinating with Medicaid CMOs, helping families enroll in Medicaid, and managing IEP-related care coordination.

School-Based Health Centers in Georgia

A substantial network of School-Based Health Centers operates inside Georgia schools. SBHCs are clinical practices physically located on school grounds, typically inside or adjacent to a school building, providing primary care and other services to all students regardless of insurance status. SBHCs are operated by:

• Federally qualified health centers (FQHCs), the most common operating model
• Hospital systems (Children's Healthcare of Atlanta, Emory Healthcare, Augusta University Health, Memorial Health Savannah, Northeast Georgia Health System)
• Local health departments
• Community mental health providers in some cases

SBHCs offer:

• Primary care: well-child visits, sick visits, immunizations, sports physicals, EPSDT screening, chronic disease management.
• Behavioral health: counseling, mental health assessment, crisis intervention, often in partnership with Georgia APEX program or DBHDD-contracted providers.
• Dental services: some SBHCs offer on-site dental care; others coordinate with mobile dental programs or community dental providers.
• Vision services: some SBHCs offer vision screening and provide referrals for eyeglasses; others coordinate with mobile vision programs.

SBHC services are billable to Medicaid under the Free Care Reversal of 2014. SBHCs also bill private insurance for privately insured students and operate sliding-scale fee structures for uninsured students. HRSA grants, Medicaid revenue, private insurance billing, and state grants combine to fund SBHC operations.

Parental consent is required for SBHC care delivery and Medicaid billing. Some adolescent services follow Georgia minor consent law for confidentiality (pregnancy testing, contraception, STI testing, mental health under specific provisions).

The Georgia APEX school mental health program

The Georgia APEX (Apex) program launched in the mid-2010s with state and federal funding to expand school-based mental health. APEX contracts with community mental health providers (community service boards and behavioral health agencies) to deliver behavioral health services inside schools. APEX-contracted providers offer:

• Individual therapy
• Group therapy
• Crisis intervention
• Behavioral assessment
• Coordination with families and school personnel
• Tele-psychiatry for medication management
• Referrals to higher levels of care when needed

APEX was expanded substantially through the Bipartisan Safer Communities Act of 2022 funding. The program now operates across many Georgia schools in districts of all sizes. Medicaid-enrolled students receive APEX services billed to Medicaid; privately insured students may have services billed to private insurance; uninsured students receive sliding-scale or grant-funded services.

APEX is administered by the Georgia Department of Behavioral Health and Developmental Disabilities with funding from state appropriations, federal grants, and Medicaid revenue. The program addresses the substantial workforce shortage in child and adolescent psychiatry and the geographic concentration of mental health providers in urban areas by bringing services to where students are.

Tele-school-based services

Tele-school-based services use audio-video telehealth to deliver services to students in rural districts or districts with workforce shortages. Common tele-school-based applications include:

• Tele-psychiatry: A child psychiatrist at an academic medical center provides medication management to students in a rural district via audio-video.
• Tele-therapy: Occupational therapy, physical therapy, and speech-language pathology services delivered via audio-video for districts without on-site therapists.
• Tele-mental health: Counseling and behavioral support delivered through Georgia APEX or other partnerships.
• Tele-EPSDT: Some routine screening services delivered via audio-video.

Tele-school-based services are reimbursable to Medicaid under the same telehealth coverage rules that apply to other Medicaid telehealth services. The school typically serves as the originating site, with a school nurse or counselor present to support the student during the visit. The Free Care Reversal and the 2014 SMDL guidance support broad Medicaid coverage of tele-school-based services for Medicaid-enrolled students.

Service categories in detail

Speech-Language Pathology (SLP)

Speech-Language Pathology is the most common IDEA-Medicaid service in Georgia. SLP addresses articulation disorders, fluency disorders (stuttering), receptive and expressive language disorders, augmentative and alternative communication (AAC), and pragmatic communication. Covered codes include the standard SLP treatment and evaluation codes; consult the current DCH Medicaid School-Based Services Provider Manual for specifics.

Occupational Therapy (OT)

Occupational Therapy addresses fine motor skills, sensory regulation, activities of daily living, handwriting, and self-care skills. Covered codes include the standard OT evaluation and therapeutic-activity codes; consult the current DCH Medicaid School-Based Services Provider Manual for specifics.

Physical Therapy (PT)

Physical Therapy addresses gross motor skills, mobility, balance, equipment training, and transfer training. Covered codes include the standard PT evaluation and therapeutic-exercise codes; consult the current DCH Medicaid School-Based Services Provider Manual for specifics.

Audiology

Audiology services include hearing assessment, hearing aid programming, and central auditory processing evaluation.

Vision services

Vision services include vision assessment and adaptive supports for students with visual impairment.

Behavioral health

Behavioral health services on IEPs include counseling, behavior support, and crisis intervention. Behavioral health services through SBHCs and Georgia APEX expand the reach beyond IEP-only services.

School nursing for chronic conditions

School nursing services for chronic medical conditions on IEP include diabetes management (blood glucose monitoring, insulin administration), seizure management (rescue medications), tracheostomy care, gastrostomy feedings, and other complex medical needs. These services are Medicaid-billable when specified on the IEP.

Transportation

Transportation is Medicaid-billable when specified on the IEP as a related service for students who require specialized vehicle access due to disability.

Parental consent requirements

IDEA requires schools to obtain parental consent to bill Medicaid for IEP services under federal regulations. Schools must:

• Provide annual written notice to parents about Medicaid billing.
• Obtain one-time consent for Medicaid billing that can be revoked at any time.
• Continue providing IEP services regardless of whether the parent consents to Medicaid billing.

Parental consent for Medicaid billing is separate from IDEA consent for service delivery. A parent can decline Medicaid billing without affecting the child's IEP services. Some parents decline Medicaid billing because they are concerned about Medicaid utilization records affecting future eligibility (an unfounded concern in most cases) or because they prefer to use private insurance for related services delivered outside school.

For SBHC primary care services, parental consent is required for both care delivery and Medicaid billing. Some adolescent services follow Georgia minor consent law for confidentiality: pregnancy testing, contraception, STI testing, and certain mental health services may be provided to minors with confidential billing in specified circumstances.

Six worked examples

Aisha: speech-only IEP and Medicaid billing in Atlanta

Aisha is 7 years old and in second grade at her elementary school in Atlanta Public Schools. In kindergarten, her teacher noticed significant articulation difficulties. Her speech sound errors were inappropriate for her age. The IEP team conducted a comprehensive evaluation including hearing screening, oral mechanism examination, articulation assessment, and language assessment. Aisha was found eligible for special education under the speech-language impairment category.

Aisha's IEP includes speech-language pathology services twice per week, 30 minutes per session, in pull-out setting (Aisha leaves the regular classroom for SLP services in the SLP's office). The IEP team set goals for production of specific speech sounds in conversational speech.

Aisha's mother is enrolled in Georgia's Pathways to Coverage program through work-requirement compliance, and Aisha is enrolled in standard Medicaid through Amerigroup Community Care. Atlanta Public Schools obtained Aisha's mother's consent for Medicaid billing during the IEP development process. The district bills Medicaid for SLP services under the applicable treatment code, with documentation maintained in Aisha's special education file and billing records maintained separately.

After 2 years of SLP services, Aisha's articulation has improved to age-appropriate norms. The IEP team will conduct a reevaluation to determine whether continued SLP services are needed.

Marcus: SBHC and tele-psychiatry in Macon

Marcus is 14 and in 8th grade at a middle school in Bibb County (Macon area). Marcus has ADHD and co-occurring oppositional behavior. He was identified for special education under the Other Health Impairment (OHI) category. His IEP includes small-group academic support, school counselor sessions weekly, and behavioral support plan.

Marcus's school has an SBHC operated by Atrium Health Navicent that serves all students in the school. Marcus's family enrolled him at the SBHC for primary care. The SBHC nurse practitioner conducted a comprehensive well-child visit and referred Marcus for tele-psychiatry to manage his ADHD medication.

The tele-psychiatry visits are conducted via audio-video from the SBHC, with a child psychiatrist at Atrium Health Navicent providing care. Marcus receives monthly tele-psychiatry visits for stimulant medication management. The SBHC nurse supports Marcus during visits and ensures continuity with his teachers and the school counselor.

Marcus is enrolled in PeachCare for Kids through CareSource. Both the SBHC primary care and the tele-psychiatry are billed to CareSource under the post-Free Care Reversal rules and the telehealth coverage rules described in the companion telehealth guide.

Tonya: pregnancy services through the SBHC in Albany

Tonya is 16 and in 10th grade at a high school in Dougherty County (Albany). The school has an SBHC operated by a local FQHC. Tonya becomes pregnant and visits the SBHC for pregnancy testing, using confidentiality protections for pregnancy-related services under Georgia minor consent law.

The SBHC nurse practitioner confirms the pregnancy and counsels Tonya on options. Tonya decides to continue the pregnancy. The nurse practitioner helps Tonya enroll in Pregnancy Medicaid through Peach State Health Plan and refers her to a community OB-GYN partner for prenatal care. The SBHC continues to provide ongoing well-visits and prenatal coordination after enrollment is established.

The SBHC bills Medicaid for pregnancy-related services after Tonya's enrollment is established, with billing arrangements that protect Tonya's confidentiality consistent with Georgia minor consent law and SBHC policy.

Jamil: autism IEP plus COMP Waiver coordination in Savannah

Jamil is 9 and in 3rd grade at an elementary school in Chatham County (Savannah). Jamil has autism spectrum disorder with significant communication and behavioral needs. He has been on an IEP under the autism category since pre-K. His IEP includes special education classroom, SLP 3 times per week, OT 2 times per week, behavior support, and use of an augmentative and alternative communication (AAC) device for receptive and expressive language.

Jamil also enrolled in the COMP Waiver (described in the companion NOW and COMP waivers guide) when he was 8, after a Crisis Status approval following his father's death. Jamil's COMP Waiver covers Community Living Supports at home, intensive behavior supports, and respite for his mother.

The school district and DBHDD coordinate to avoid double-counting between IDEA-Medicaid billing for school-based SLP, OT, and behavior support, and COMP Waiver billing for after-school behavior support and Community Living Supports. The Support Coordinator and IEP team meet quarterly to ensure coordinated planning and clear delineation of which services are funded through which mechanism.

Jamil's Medicaid is administered through Wellpoint CMO. SLP and OT are billed to Wellpoint through the district's school-based Medicaid billing process. COMP Waiver services are billed separately through DBHDD-contracted providers.

Sarah: Section 504 plus Georgia APEX in Columbus

Sarah is 17 and a junior at a high school in Muscogee County (Columbus). Sarah has major depressive disorder, identified by her school counselor through a routine screening in 10th grade. Sarah's symptoms include persistent low mood, decreased interest, sleep disturbance, and academic decline.

Sarah does not have an IEP because her depression does not affect her academic functioning at the level required for IDEA eligibility under the emotional disturbance category. Instead, she has a Section 504 Plan that provides accommodations: extended time on tests, breaks during the school day, modified deadlines, and a check-in routine with her school counselor.

Section 504 services are not Medicaid-billable in the same way as IEP services, because they are accommodations rather than direct services. However, Sarah accesses tele-psychiatry through the Georgia APEX program, which partners with a community mental health provider that delivers tele-therapy and tele-psychiatry inside her high school. Sarah meets weekly with an APEX-contracted therapist via audio-video for cognitive behavioral therapy and monthly with an APEX-contracted psychiatrist for SSRI medication management.

Sarah's Medicaid is through Wellpoint CMO. APEX services are billed to Wellpoint as standard Medicaid behavioral health services delivered in a school setting under the post-Free Care Reversal framework.

Tyrell: SBHC primary care for asthma in rural Athens area

Tyrell is 6 and in kindergarten at a small elementary school in a rural district outside Athens. Tyrell has moderate persistent asthma. His school has an SBHC operated by a regional FQHC, providing primary care for all students.

Tyrell's parents enrolled him at the SBHC because the closest primary care medical home is 25 miles away in Athens. The SBHC delivers Tyrell's well-child visits, EPSDT screening, immunizations, and ongoing asthma management. Tyrell has an Asthma Action Plan coordinated between the SBHC, the school nurse, and Tyrell's parents. Inhalers (albuterol for quick relief and fluticasone for daily controller) are kept at school under physician orders, and the school nurse administers as needed.

Tyrell is enrolled in PeachCare for Kids through Peach State Health Plan. The SBHC bills Peach State for well-visits, asthma management, immunizations, and EPSDT screening under the post-Free Care Reversal framework.

Things commonly missed

1. The Free Care Reversal of December 2014 enables broad school-based Medicaid coverage: This SMDL is the single most important federal policy change for school-based Medicaid in the past decade.

2. IDEA services on IEP are billable to Medicaid for Medicaid-eligible students: With parental consent for billing, school districts can claim federal Medicaid match for IEP-specified services.

3. Parental consent for Medicaid billing is separate from IDEA consent: A parent can refuse Medicaid billing without affecting the child's IEP services. Schools must obtain Medicaid billing consent annually and respect parental decisions.

4. The Random Moment Time Study (RMTS) methodology: Quarterly sampling allocates costs between IDEA and Medicaid funding to prevent double-counting.

5. Medicaid Administrative Claiming (MAC): Covers IDEA-related administrative activities and is separate from direct service billing.

6. Georgia school districts vary substantially in SBS program maturity: Large urban and suburban districts typically have established billing operations; smaller rural districts may not bill Medicaid at all.

7. SBHCs are distinct from IEP services: SBHCs operate under separate authority and funding from IEP services and serve all students regardless of disability status.

8. Tele-school-based services are expanding rapidly post-COVID: The Free Care Reversal combined with the broader telehealth coverage framework supports tele-school-based services for Medicaid-enrolled students.

9. FERPA versus HIPAA boundary: Education records under FERPA; health records under HIPAA. School-Medicaid billing operates at the boundary and requires coordination.

10. IDEA Part C (ages 0-3) is Babies Can't Wait: Georgia's early intervention program is separate from school-based services and serves infants and toddlers with developmental delays.

11. Section 504 accommodations are different from IEP services: Section 504 plans provide accommodations rather than direct services and generally are not Medicaid-billable as IEP services.

12. Adolescent confidentiality for some SBHC services follows Georgia minor consent law: Pregnancy testing, contraception, STI testing, and certain mental health services may be confidential.

13. The Bipartisan Safer Communities Act of 2022 funded mental health expansion: BSCA accelerated APEX program growth and tele-school-based mental health.

14. Georgia APEX program: Launched in the mid-2010s, expanded substantially with BSCA 2022, providing tele-psychiatry and behavioral health counseling in schools.

15. Children in foster care often have IEPs and Medicaid simultaneously: DFCS, school district, and Medicaid CMO coordinate to support these students.

16. McKinney-Vento homeless students retain IDEA and Medicaid rights: Regardless of housing status.

17. Charter schools and private schools have different IDEA obligations: Charter schools comply with IDEA Part B if they receive federal funds; private schools have limited IDEA obligations but parentally placed private school students retain some rights.

18. Out-of-pocket cost-sharing is prohibited for IDEA services regardless of Medicaid billing: Schools cannot charge families for IDEA services regardless of insurance status.

19. Speech-language therapy is the most common IDEA-Medicaid service: OT and PT are also frequently billed, but SLP dominates the IDEA-Medicaid claim mix.

20. District-level Medicaid billing revenue can fund program expansion: Districts that effectively bill Medicaid recover federal match revenue that can support additional related services personnel, supplies, and program improvements.

Frequently asked questions

How to navigate school-based Medicaid services

For parents of Medicaid-enrolled students, the practical steps for navigating school-based services are:

1. Engage with the IEP team: If your child has a disability that affects learning, request an IEP evaluation. The IEP team will determine eligibility and develop services.

2. Provide Medicaid billing consent: When the IEP team or special education office requests Medicaid billing consent, understand that it does not affect your child's IEP services. Consent supports federal funding that strengthens the district's program.

3. Connect with the SBHC if one is in your child's school: SBHCs provide convenient primary care and behavioral health services for all students. Enroll your child if the school has an SBHC.

4. Ask about Georgia APEX or tele-school-based services: If your child needs behavioral health support or specialty consultation, ask the school counselor or principal whether APEX or tele-school-based services are available.

5. Coordinate with your CMO: Your CMO (Amerigroup, CareSource, Peach State Health Plan, or Wellpoint) manages your child's Medicaid managed care benefits. The CMO can help coordinate services between school-based providers and community providers.

6. Maintain medical records and IEP records: Both records are important for your child's care. The school maintains the IEP under FERPA; medical providers maintain health records under HIPAA. You have rights to access both.

7. Advocate for your child's needs: If you feel IEP services are insufficient or if access to school-based services is limited, engage with the IEP team, the special education office, and external advocates (Parent to Parent of Georgia, Disability Rights Georgia, GCDD).

8. Plan transitions: As your child moves between grade levels, school buildings, or school districts, ensure IEP and Medicaid records transfer smoothly. Foster care transitions, family relocations, and high school graduation require careful coordination.

Putting it all together

Georgia's school-based Medicaid services framework supports a substantial expansion of healthcare access for Medicaid-enrolled students across the state. From the IEP-driven speech-language therapy delivered to thousands of elementary school students with articulation disorders, to the SBHC primary care that provides immunizations and asthma management in rural elementary schools, to the tele-psychiatry that connects high school students with depression to child psychiatrists at academic medical centers, to the Georgia APEX school mental health counseling that has expanded substantially through Bipartisan Safer Communities Act funding, schools have become major sites of healthcare delivery for low-income children in Georgia.

The framework is anchored federally by the Medicare Catastrophic Coverage Act of 1988, IDEA Part B, the EPSDT comprehensive children's benefit, the December 2014 Free Care Reversal State Medicaid Director Letter, and the Bipartisan Safer Communities Act of 2022. It is implemented in Georgia through the state special-education statute, the Georgia Medicaid State Plan, the DCH-GADOE Interagency Agreement, the DCH Medicaid School-Based Services Provider Manual, and the Random Moment Time Study methodology that allocates costs between IDEA and Medicaid funding streams. Georgia school districts implement the program with varying maturity, supported by the statewide network of School-Based Health Centers and the Georgia APEX program for school-based mental health.

For families with a Medicaid-enrolled student, the most important first step is engaging with your child's school: understand whether your child has or needs an IEP, whether the school has an SBHC, whether Georgia APEX or tele-school-based services are available, and provide Medicaid billing consent when requested. The federal Medicaid match revenue that flows back to the school district when families consent to Medicaid billing supports program expansion for all students, with no negative effects on your child's services. For comprehensive Medicaid, special education, and eldercare guidance across Georgia and nationally, brevy.com publishes updated guides on Medicaid coverage, IDEA implementation, school-based health, and the federal-state policy frameworks that shape access to care.

This guide is for general information only and does not constitute medical, legal, educational, or insurance advice. School-based Medicaid coverage rules, IDEA implementation, and Georgia APEX program details are subject to change. Always confirm current rules with your school district, your child's IEP team, your CMO, and the Department of Community Health. For special education advocacy, contact Disability Rights Georgia, Parent to Parent of Georgia, or the Georgia Council on Developmental Disabilities.

Find personalized help navigating Georgia at brevy.com.