Local Educational Agency Billing Option Program

What is Local Educational Agency Medi-Cal Billing Option Program (LEA BOP)?

LEA BOP is an optional program overseen by the California Department of Health Care Services (DHCS) for LEAs to recoup allowable expenses for providing covered health services for students enrolled in Medi-Cal, California’s Medicaid program. LEA BOP is an ongoing funding stream through reimbursement for services, where LEAs receive federal matching funds for state and local dollars spent on eligible services.

LEA BOP is a Certified Public Expenditure (CPE) program, a mechanism for public entities, such as LEAs, to certify that the funds spent on Medicaid services are eligible for federal matching funds. Therefore, the program has several components to ensure participating LEAs comply with CPE requirements.

The LEA BOP offers an incredible opportunity to improve health outcomes for California’s student Medi-Cal beneficiaries. This reimbursement program can help improve access to prevention and treatment services for students enrolled in Medi-Cal.

This overview page briefly describes (and links sites) how LEA BOP can benefit LEAs, how to get started with the program, the administrative basics of the program, and compliance requirements. For more information, refer to DHCS’s LEA Medi-Cal Billing webpage and the LEA BOP Handbook PDF .

Please note that this guidance does not constitute legal advice and is not binding. For questions about the implications of the information on this web page on local programs or specific circumstances, LEAs should consult their local counsel.

LEA BOP Process

Hire: LEA hires practitioners (employed or contracted) based on annual school budget.

Claim: The LEA submits a claim to Medi-Cal for LEA BOP-covered direct services.

Reimburse: Medi-Cal sends interim reimbursement based on claims.

Certify: The LEA reconciles reimbursements with actual costs through a cost report.

Audit: DHCS audits actual costs to verify that they are allowable expenditures.

Payment: LEA receives settlement payments within 18 months of cost report submission.

LEA BOP Participants and Optional Supports

Individual LEAs participating in the program are identified as LEA BOP Providers. Once enrolled in LEA BOP, the LEA is considered a Medi-Cal provider.

An LEA BOP Provider can choose to utilize optional supports including an LEA Billing Consortium and/or a third-party billing vendor.

LEA BOP Providers

• School District
• County Office of Education
• Charter School
• State Special School
• Community College District
• California State University Campus
• University of California Campus

LEA Billing Consortium

• Two or more LEA BOP Providers pooling their resources to provide LEA BOP services and billing under one National Provider Identifier (NPI) number.
• LEA BOP Providers may seek assistance from other larger LEA BOP Providers to share administrative billing resources to support medical services provided to beneficiaries.

LEA Billing Agent/Vendor

• Optional for-profit third party contracted to assist LEA BOP providers with billing and claims submissions.

The LEA is responsible for assigning staff to manage its participation with the LEA BOP. This responsibility typically falls to the LEA BOP/Medi-Cal Billing Coordinator or Manager, and in many cases, it may fall to more than one staff to oversee the administration of the LEA BOP at the LEA level. Depending on the LEA’s size, these may be duties that fall under one of the following positions:

• Special Education Director/Manager
• District School Nurse
• Business Manager
• One or more dedicated, full-time position(s)

Regardless of who oversees program participation, the coordinator should work closely with the following people to support program participation and compliance:

• Business Manager and/or finance office
• Special Education Director/Program manager
• Human Resources
• School Health Practitioner Supervisors
• Contracts staff
• IT staff
• Administrative Unit

LEA Participant Contact and Mailing Information

LEAs should sign up for these updates through the e-mail subscription service on the LEA BOP website .

It is essential that anytime an LEA participant has a change to their contact and mailing information, they must inform DHCS of those changes immediately and not wait until the Annual Report submission. Late notice can result in missing essential program changes, reimbursements, and updates.

LEA BOP Policy and Procedure Letters

DHCS issues policy and procedures regarding the LEA BOP via Policy and Procedure Letters (PPLs). These notifications alert LEA participants of procedure updates and changes as well as any new or shifting policies. They can be in response to state or federal mandates, codes, regulations, or moving program policies. These PPLs are valuable for guiding your LEA through a successful, compliant, and effective program.

Current DHCS LEA BOP PPLs are on the LEA Medi-Cal Billing Option Program Policy and Procedure Letters webpage . PPLs are typically released several times a year, so LEAS need to sign up for the e-mail subscription service on the LEA BOP website, read PPLs carefully when released, and adjust accordingly if needed.

Eligible Services

LEA BOP covers assessment, treatment, and targeted case management services for special education and general education students, including recommended preventive pediatric health care as published by the American Academy of Pediatrics. LEA BOP also covers medical transportation for special education students. A list of covered assessments and treatments may include services your LEA already provides to students, including those listed below:

• Hearing Services
• Health, Mental Health Evaluation and Education Assessments
• Nursing Services and Activities of Daily Living
• Nutritional Services
• Occupational Therapy
• Orientation and Mobility
• Physical Therapy
• Physician Services
• Psychology/Counseling
• Respiratory Care
• Specialized Medical Transportation
• Speech Therapy
• Targeted Case Management (TCM)
• Vision

Eligible Practitioners

To provide the covered services, LEA BOP includes many kinds of practitioners, many of which are staff that your LEA likely already employs. These will be direct service practitioners who regularly perform and are eligible to bill for immediate medical services under the LEA BOP. To bill for services an eligible practitioner provides, that practitioner must be on an LEA’s pre-determined Time Survey Participant (TSP) List.

Familiar eligible practitioners include, but are not limited to:

• Credentialed Speech-Language Pathologists
• Credentialed School Counselors
• Credentialed School Psychologists
• Credentialed School Social Workers
• Licensed Marriage and Family Therapists
• Licensed Registered Nurses
• Licensed Physical Therapists
• Licensed Occupational Therapists

A complete list of eligible practitioners, along with more detailed descriptions of practitioner qualifications, can be found in the LEA BOP Medi-Cal Provider Manual .

Accounting for Costs

As described in Section 2, the LEA BOP is a Certified Public Expenditure (CPE) program where LEAs must certify the costs of delivering eligible services to students. LEAs account for and document their costs in a few key ways:

• Interim reimbursements for covered services provided.
• Time spent on covered services, documented quarterly through the Random Moment Time Surveys (RMTS).
• Yearly submission of the Cost and Reimbursement Comparison Schedule (CRCS), which requires LEAs to account for and reconcile costs of services rendered against interim reimbursements received. DHCS then audits the CRCS to determine the final settlement.

This section briefly overviews interim claims, the RMTS, the CRCS, and the audit timeline. More information can be found in the DHCS Medi-Cal Provider Manual .

Claims and Interim Reimbursement

LEAs must be prepared to submit claims for LEA BOP-covered services a qualifying practitioner provides through electronic billing within 12 months of the service date. LEAs will be paid interim reimbursements based on these claim submissions. After submitting the cost report, LEAs will receive interim settlements within 12 months, based on the reconciliation of interim claims with actual costs calculated in the cost report, and final settlements within 18 months. LEAs must become submitters for electronic claims during the last step of the LEA BOP enrollment process (see Section 3). The Provider Enrollment Division (PED) may deactivate the National Provider Number (NPI) from the Medi-Cal claiming system if a reimbursement claim has not been submitted for 12 months, in which case LEAs may have to re-enroll to claim for LEA BOP services.

Random Moment Time Survey (RMTS)

The RMTS is a time study mechanism, overseen by LEA BOP and School-Based Medi-Cal Administrative Activities (SMAA), used to determine the amount of time spent on activities throughout a participant’s workday. The RMTS is administered quarterly in quarters two through four, starting with quarter two in October. All eligible practitioners employed by the LEA and included on the CRCS must be on the Time Survey Participant (TSP) list. Eligible practitioners on the TSP lists, which are updated quarterly, may receive a notification to respond to a “random moment” which captures what they are doing in the specific minute that is assigned. Those responses are then coded as either a billable or non-billable activity. The total of all billable codes is then formulated into percentage of all moment responses that creates the Direct Medical Services Percentage (DMSP), which is part of the payment methodology shown below. A minimum 85% compliance response rate is required for each LEA, but the goal should be 100% as the rate is tied to the Direct Medical Services Percentage. Participation in the RMTS is required in order to submit employee costs on the CRCS and receive reimbursement for their covered services. To participate in RMTS your LEA will need to contract with your Local Educational Consortium (LEC). Please consult the Service Regions Map and Contact Information to connect with your LEC.

Cost Reimbursement

LEAs are not reimbursed for the entirety of total service costs, and there are factors other than cost that impact reimbursement. The total allowable Medi-Cal cost is calculated using four indicators outlined below.

Total cost: The total allowable cost of providing services, which typically includes salaries, benefits, contracts, and necessary supplies.

Federal Medical Assistance Percentage (FMAP): The percentage of costs that the federal government will cover. This is typically 50 percent and is consistent across all LEA BOP Providers.

Medi-Cal Eligibility Ratio (MER): The MER represents the percentage of an LEA’s total enrolled students that are LEA BOP eligible and enrolled in Medi-Cal. The MER percentage is applied in the CRCS to allocate costs to the Medi-Cal Program.

Direct Medical Services Percentage (DMSP): The percentage of time spent on direct services covered by LEA BOP for all LEAs within each Random Moment Time Survey (RMTS) region. This percentage is determined by the RMTS (described above).

Resources and Definitions

References and Resources
LEA BOP providers are ultimately responsible for administrative functions and should be familiar with the LEA BOP website, DHCS policies, program regulations, and the LEA BOP Provider Manual .

Local Educational Agency Medi-Cal Billing Option Program Provider Manual
The relevant sections of the LEA BOP Provider Manual are on the program website. They cover specific policies, CPT code lists, claiming and billing information, and information about service categories. Any LEA BOP Provider Manual updates will be published online and providers will be notified through the Medi-Cal Updated Bulletin for LEAs .

LEA BOP Policy and Procedure Letters
DHCS issues policies and procedures regarding the LEA BOP via Policy and Procedure Letters (PPLs). These notifications inform LEA participants of procedure updates, changes, and any new or shifting policies. PPLs can be issued in response to state or federal mandates, codes, and regulations, or shifting program policies. These PPLs are a valuable resource for guiding your LEA through a living, breathing Program.

The entire DHCS LEA BOP PPLs repository can be found on the LEA Medi-Cal Billing Option Program Policy and Procedure Letters webpage .

LEA BOP Tool Box
DHCS developed an online Tool Box to give providers quick access to valuable resources and information concerning the proper administration and management of the LEA BOP. Resources in the Tool Box include tip sheets, important program documents, information about relevant state and federal policies, and helpful links to essential materials, including the Provider Manual.

Program Guide
DHCS developed a collection of fiscal and program compliance information regarding processes, documentation, and guidance necessary for successful participation in LEA BOP, as required by Welfare and Institutions (W&I) Code Section 14115.8. The Program Guide includes but is not limited to state plan and state plan amendments (SPAs), frequently asked questions, policy and procedure letters, trainings, provider manuals, and other relevant types of instructional materials.

Key Contact Information

Inquiry	Contact
LEA BOP Questions or Comments Policy questions Compliance document request Enrollment Change of address/contact Technical assistance requests Questions about CRCS	LEA@dhcs.ca.gov LEA Medi-Cal Billing Website
LEA BOP Compliance Documents and Annual Report Submitting compliance documents like the Annual Report and Data Use Agreement forms Requesting extensions	LEA.AnnualReport@dhcs.ca.gov
DHCS Cost and Reimbursement Comparison Schedule Submitting CRCS or requesting an extension	LEA.CRCS.Submission@dhcs.ca.gov
DHCS Random Moment in Time Survey (RMTS)	RMTS@dhcs.ca.gov RTMS Website
Audits and Investigations Questions related to audits of the CRCS	LEAAuditQuestions@dhcs.ca.gov
Medi-Cal Telephone Service Center Claims issues	800-541-5555

Website Resources

The resource list below provides the names and links to critical information, forms, policies, and more that will support LEAs in meeting LEA BOP requirements and administering a successful program.

Administration and Audit Checklist
Cost and Reimbursement Comparison Schedule
California State Plan
Internal Administrative Function Chart
LEA: A Provider’s Guide
LEA BOP Tool Box
LEA BOP Website
LEA Glossary of Terms
LEA BOP Program Policy and Procedure Letters (PPLs)
LEA Provider Manual

Other CDE Resources

CA Department of Education Home
California School Directory