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Update on School-Based Services (SBS) Medicaid Billing in Wisconsin

Be on the lookout—important updates are coming soon regarding changes to the Free Care Rule that will affect School-Based Services (SBS) Medicaid billing in Wisconsin.

What is Changing

  1. State Plan Amendment (SPA) Approved
    • Wisconsin submitted SPA # 25-0014, which was approved on August 18, 2025, and is effective July 1, 2025.
    • This SPA expands coverage and payment details for school-based services.
  2. Expansion of Which Students Qualify
    • Previously, only students with an Individualized Education Program (IEP) were eligible for many school-based services reimbursement.
    • Under the new rules, additional types of treatment/care “plans” can serve to document medical necessity, including IEPs, IFSPs, 504 Plans, health/behavioral health plans, or other individualized plans.
  3. Broader Range of Services Covered
    • Covered services still include: physical therapy, occupational therapy, speech/hearing/language services; also diagnostic, screening, preventive, and rehabilitative services. Expansion may include additional practitioner/provider types (those meeting state licensing, scope of practice) and more flexibility in who can document medical necessity.
  4. Corresponding Rule Changes to Align with the SPA
    • DHS is revising its administrative rules (DHS Chapters 105 and 107) to align with the amended state plan. These rule revisions clarify what provider types can bill, what services are reimbursable, what types of treatment plans are valid, and record-keeping/documentation requirements.
    • The proposed rules would remove the requirement that only IEPs could document medical necessity, enabling other care plans to do so.

What’s Still in Progress

  • The final list of services and provider types outside of IEPs.
  • Claiming processes and compliance details.

Contacts for Questions

SAA will continue to share updates as DHS and DPI finalize the details. Please don’t hesitate to reach out to the above contact—or your district’s Medicaid/finance lead—for specific questions.

The School Administrators Alliance (SAA) has moved to a login/membership only website. Your login is your school email address. Your password is your primary membership organization: awsa2023! Please follow this link to log in. Once logged in, you will be able to change your password and complete your profile. Two helpful instruction videos can be found here. If you have any questions or trouble logging in please contact the SAA office at 608-242-1370 or email [email protected].