School Health and Related Services

The School Health and Related Services (SHARS) program allows Texas local educational agencies (LEAs) and shared service arrangements (SSAs) to request reimbursement for Medicaid health-related services. The admission, review, and dismissal (ARD) committee determines SHARS services. Services must be medically necessary and reasonable to ensure that children with disabilities are able to participate in the educational program.

SHARS reimbursement is available for students with parental consent to release identifying information to Medicaid and who meet all of the following requirements:

  • 20 years of age and younger
  • currently eligible for Medicaid
  • enrolled in a public school's special education program
  • meet requirements for special education described in the Individuals with Disabilities Education Act (IDEA)
  • current individualized education program (IEP) that prescribes the needed services.

Services covered by SHARS include:

  • audiology services
  • counseling
  • nursing services
  • occupational therapy
  • personal care services
  • physical therapy
  • physician services
  • psychological services, including assessments
  • speech therapy
  • specialized transportation as defined by the Health and Human Services Commission (HHSC)
 

Medicaid Policy Changes Effective Oct. 1, 2022

After inviting stakeholder input, the Texas Medicaid & Healthcare Partnership (TMHP) has posted revisions to SHARS policy. 

Major changes include:

  • Students who receive audiology services under Section 504 are eligible for SHARS reimbursement;
  • SHARS coding is updated for audiology services;
  • Telehealth expansion continues;
  • Providers eligible to provide SHARS speech therapy is limited to licensed speech-language pathologists (SLP) and their interns and assistants;
  •  Personal Care Services (PCS) continues to be limited to non-educational support.

The complete list of changes is on the TMHP website.

 

Provider Service Documentation - Individualized Logs

SHARS providers are required to document service through logs.  Guidance for this requirement comes from the Texas Medicaid Provider Procedures Manual (TMPPM). As clarification was requested in the past, the Health and Human Services Commission (HHSC) developed and distributed a Frequently Asked Questions (FAQ) document. The FAQ specifies, “Service log for PCS must include the signature of the individual that provided the PCS. In cases where more than one person provided PCS throughout the day, only one person needs to sign the service log.” TEA audits confirm that districts have implemented this guidance in self-contained classrooms.  One staff member is chosen to document PCS provided by the classroom staff throughout the day.

The FAQ expired on October 31, 2021. HHSC reminds us that the current guidance document is the November 2021 TMPPM SHARS Handbook. In subsection 2.4, it includes new language regarding documentation requirements:

The SHARS provider’s printed name, title, and original handwritten or electronic signature are required components of the service log for all SHARS services, including PCS.

Therefore, there is an expectation that all service providers, including staff in self-contained classrooms, must document their own service.  TEA will enforce this expectation for documents created on or after November 1, 2021, when the FAQ expired.

If providers are not able to meet this requirement, the service should not be billed for SHARS reimbursement. Medicaid has an expectation that once providers are aware of the need to modify local practices, those changes should be made. As always, TEA is available to support LEAs as they make this transition.

 

Enrollment in SHARS 

A district must enroll as an active Medicaid provider for SHARS to become eligible to submit claims and receive reimbursement for SHARS Medicaid services.  Additional information about becoming a SHARS Medicaid provider is located on the Health and Human Services Commission website.

 

Parental Notice and Consent   

LEAs and SSAs are required to provide notification and obtain targeted parental consent before accessing a child’s or parent’s public benefits or insurance.

Written Notification 

LEAs and SSAs must provide written parental notification prior to requesting consent and accessing benefits for the first time and annually thereafter.  Minimally, it must include all of the following: 

1. A statement of the parental consent to access public benefits (34 CFR 300.154(d)(2)(iv)(A)-(B)) that

  •  specifies the personally identifiable information that may be disclosed (e.g., records or information about the services),
  •  describes the purpose of the disclosure (e.g., billing for specific IEP services), and
  •  identifies the agency to which the disclosure may be made (e.g., Medicaid).

2. A statement of the "no cost" provisions that states that states voluntary participation will not decrease lifetime benefit or incur out-of-pocket expense (34 CFR 300.154(d)(2)(I)-(iii)).

3. A statement that the parents have the right to withdraw their consent at any time (34 CFR 300.154 (d)(2)(v)(C)).

4. A statement that the withdrawal of consent or refusal to provide consent does not relieve the public agency of its responsibility to ensure that all required services are provided at no cost to the parents (34 CFR 300.154(d)(2)(v)(D)).

      The notification must be written in language understandable to the general public and in the native language of the parent or other mode of communication used by the parent, unless it is clearly not feasible to do so (34 CFR 300.154(d)(2)(v)(D) and 300.503(c)).

        One-Time Written Consent

        LEAs and SAAs  must obtain parental consent before releasing a child's personally identifiable information for billing purposes to a public benefits or insurance program for the first time.  Minimally, it must include the following:

        1. A statement of the parental consent to access public benefits (34 CFR 300.154(d)(2)(iv)(A)-(B)) that

        • specifies the personally identifiable information that may be disclosed (e.g., records or information about the services),
        • describes the purpose of the disclosure (e.g., billing for specific IEP services), and
        • identifies the agency to which the disclosure may be made (e.g., Medicaid).

          2. A statement indicating that the parent understands and agrees that the public agency may access the child’s or parent’s public benefits or insurance to pay for specific services identified in the child's IEP.

            Guidance Regarding Parental Consent for the Use of Public Benefits or Insurance

             

            Annual Cost Report Requirements

            Participating agencies are required to submit an annual cost report documenting the provider's Medicaid-allowable costs for all SHARS delivered during the federal fiscal year. This is used to reconcile interim payments to total Medicaid-allowable costs based on approved cost allocation methodology procedures. 

            HHSC is considering an amendment to 1TAC §355.8443. Proposed changes can be found beginning on page 2394 of the Texas Registry. These changes are anticipated to be in effective on October 1, 2022, but have not been approved at this time.

            TEA does not dictate this process. HHSC determines these procedures and has clarified the use of parental consent it relates to the cost report . Questions regarding this process can be directed to ProviderFinanceSHARS@hhs.texas.gov

             

            Texas Medicaid Policy: Third Party Liability (TPL) for SHARS Interim Billing

            Enrollment in SHARS is optional for districts and parents. Participation does not preclude the district's responsibility to provide a free and appropriate public education to all students with disabilities. Parents/adult students cannot be charged for special education services provided to students with disabilities. 

            On October 1, 2017, a new policy was instituted.  After Medicaid reimburses districts for SHARS services, the state may seek recovery claims from a student's private insurance.  The HHSC began a lookback period on SHARS third party liability (TPL) claims on October 1, 2020.

            School districts have the responsibility to share the TPL policy with all families participating in the SHARS program. The following steps should be taken:

            • Share the policy with parents/adult students. Ensure that they understand their right to withdraw consent to participate in SHARS.

            • If parents produces a document they believe is an insurance bill, verify whether the document is a bill.  Some documents may include an explanation of benefits (EOB) that may or may not indicate that money is owed. If it is an insurance bill, contact the Texas Medicaid Healthcare Partnership (TMHP) Contact Center at 1-800-925-9126.

            Information regarding TPL can be found on the TMHP website: Third Party Liability for SHARS Interim Claims.

             

             

            Implementation Guidance

            Oversight of SHARS is a cooperative effort between TEA and the HHSC. TEA monitor activities intended to ensure adherence to Medicaid standards and ensure the implementation of quality student services.

            TEA support includes:

            • monitoring compliance with documentation guidelines,
            • performing regular desk reviews and field audits,
            • providing policy clarifications to districts,
            • validating data submitted for SHARS billing,
            • working to minimize exposure to provider waste, program abuse, and fraud.

            The SHARS Self-Monitoring Tool is an instrument that can be used to assess a LEA's compliance with SHARS standards.  It is relevant to SHARS policy prior to November 2021.

            The SHARS Self-Monitoring Tool- Nov. 2021 is an updated instrument that can be used to assess compliance with the revised SHARS policy.

              

            Additional Resources and Training

            Texas Medicaid  Provider Procedures Manual-

            Personal Care Services: What It Is and What It Is NOT

            Payment Rates - Interim Billing

            SHARS Update: Electronic Bulletin Registration

            Office of Inspector General (US Department of Health and Human Services): Centers for Medicare and Medicaid Services (CMS)