Questions and Quandaries, part 1
You’ve got questions, and I love compiling a ton of information across the internet into answers! We’re the perfect match. In this week’s Q&Q post, we dive into 504s, therapy, and Medicaid…oh my!
My child is on a 504 plan, but mental health services – like therapy – are not included. I feel strongly that they would benefit from having someone to talk through their negative thought patterns with. I worry that if they don’t have opportunities to address their negative thoughts, we won’t see the benefit of the academic support. Can I ask the school to provide therapy services or pay for a therapist we find?
Where would I start if a parent asked me this question?
I would start with asking this parent if they’d shared their concerns with the school team. Parents are understandably reluctant to share with teachers or other school administrators that their child is struggling with their mental health – like engaging in negative thought patterns. A parent may hesitate to tell a school team about their concerns because 1) they’re afraid of their child being "labeled" with a mental health disorder or 2) they worry about their child having to deal with the unfortunate stigma that can be attached to individuals struggling with or needing support for their mental health.
However, even if it feels uncomfortable, it’s important for families to share these concerns with the school team. Hopefully, the team has made consistent efforts to communicate with the family and ensure they feel supported. But, even with communication and support, parents may hold back from sharing concerns.
In order for a school team to have the whole picture of the student in that moment – both at home and at school – I encourage parents to share as much as they’re comfortable sharing. There is an advantage to informing the school team so they have the information necessary to adjust a student’s plan and collaborate with the parents. A school team won’t know that a student’s plan needs updating or that the student could benefit from additional accommodations if they aren’t aware of new or growing concerns.
What is a 504 plan?
A 504 plan is a federal law that protects students through The Rehabilitation Act of 1973 against disability-based discrimination. Any educational program or activity receiving federal funding must adhere to this law. 504 plans are developed to ensure students with disabilities have the same educational opportunities as their peers without disabilities. 504 plans provide students with services, accommodations, and other appropriate support to access the educational environment and ensure the student receives a Free Appropriate Public Education (FAPE).
Students who are identified as having a disability – and eligible for a 504 plan – are entitled to a wide variety of services and accommodations tailored to their specific strengths and needs. But, before a student can access these services, accommodations, and supports, they must be evaluated to determine the disability category (or categories) under which they are eligible. During the course of the evaluation, a team of educational experts – a Section 504 Team – conduct assessments and gather information about the student’s current performance, strengths, needs, and history (academic, medical, and family).
After the evaluation process has determined the student’s eligibility, the team makes recommendations via a 504 plan. These recommendations are specific to what a student needs in the school – or educational – environment. Students may also require certain accommodations to meaningfully access or benefit from available educational opportunities.
What type of mental health supports can a school provide?
A school psychologist, counselor, or social worker can provide counseling to your child. This service would take place during school hours and on campus in a separate location from your child’s classroom(s). A 504 plan can recommend counseling or therapy as a service a student would receive during the school day. This can be an important support for students with mental health conditions – like negative thought patterns – that have an impact on their ability to learn.
In addition to or as the main type of support, schools can offer accommodations as part of a 504 plan to address mental health needs. In addition to direct services, like school-based counseling or therapy, a 504 plan can include accommodations that are critical for students seeking support for mental health conditions.These accommodations should be customized to meet the student’s specific needs and help alleviate any mental health related barriers that could hinder their access to the curriculum and classroom environment.
Example of such accommodations include:
A "safe person" on campus, like a counselor, who is available for check-ins.
Scheduled or as-needed breaks in the classroom or in another designated space.
A permanent hall pass to visit their “safe person” – like the school counselor's office.
Adjusted schedules to allow for counseling or therapy appointments.
A 504 plan can include counseling or therapy services if a student is found eligible under a disability category like anxiety or depression. Even if a student is eligible to receive services through their 504 plan, the services are limited to those the school can “reasonably provide”.
In other words, schools’ services are meant to support a student with disabilities to access the curriculum, classroom environment, and other educational programs and activities. This access must be equal to their peers without disabilities. School-based counseling or therapy is a mental health service that schools and school staff can reasonably provide.
How will the school handle paying for your child’s services if they’re on a 504 plan?
If a 504 team determines that a student needs health-related services – like counseling or therapy – as part of their plan to ensure they are accessing FAPE, Medicaid can be involved. While Medicaid will not be the primary payer, it can help to pay after a school bills any other potential payers – like private health insurance. Basically, a school can bill Medicaid for any costs remaining after seeking reimbursement through other channels.
If your student has Medicaid – for Washington residents, Apple Health or Children’s Health Insurance Plan (CHIP) – for health insurance, school health services – like those needed to support a student’s mental health – can be covered by Medicaid. As long as a professional – school-based or private – has determined a student would benefit from mental health services, they can be covered, even partially, by Medicaid. Even if a student isn’t actively receiving support through a 504, and IEP, or an IFSP, they may be eligible for reimbursement through Medicaid.
What does this look like specifically in Washington State?
Washington State public school districts, educational service districts (ESDs), public charter schools, and tribal schools are all eligible to participate in the School Based Health Services (SBHS) program through Washington State’s Health Care Authority (HCA). The SBHS program offers Medicaid-covered health care services to students in Washington state public schools. SBHS is provided through The Office of Superintendent of Public Instruction (OSPI).
OSPI is the primary state agency that oversees K–12 public education in Washington state, and it allocates funding and provides tools, resources, and technical assistance to ensure every student in Washington has access to FAPE. Working toward the same ends, Washington State’s HCA oversees how SBHS programs are delivered.
The SBHS program is an optional Apple Health program that reimburses public schools for special education health-related services – like counseling and therapy.
How does Medicaid billing for your child’s services work?
School districts that want to bill Medicaid sign a contract with the state Medicaid agency and the HCA. School districts then submit their costs for Medicaid-covered services to the state’s HCA. THe HCA reimburses the school’s costs by billing Medicaid for those services. School district staff are responsible for filling out the Medicaid forms, which can mean the district provides training for them to learn.
Luckily for school district staff, in 2023, a new federal law (the Bipartisan Safer Communities Act) required that Medicaid make the billing process easier for schools. The law requires Medicaid to make updates to outdated billing guides. It also provides more guidance to school districts who want Medicaid to reimburse them for school-based healthcare services.
A primary purpose of this law was to make billing Medicaid simpler and less expensive for schools. A secondary purpose was to encourage states to allow schools to use Medicaid for more types of healthcare services – including funding for mental health services – like counseling or therapy – for students.
If a school or district is not currently participating, what are some ways parents can advocate for a school to start billing Medicaid?
If your child’s school or school district isn’t currently set up to bill Medicaid for mental health services, parents can advocate for the school/district to enroll. Parents can ask the school principal or a superintendent about what would need to change for the district to start billing Medicaid. This information is useful for gathering support from other parents, school personnel, and local policymakers.
There are national and statewide organizations that want to expand the use of Medicaid to pay for school-based services for all Medicaid-eligible students – including students with 504 plans, IEPs, and IFSPs. These organizations provide information about advocacy and how to organize others advocating for Medicaid billing, including:
Washington School-Based Health AllianceHealthy Schools Campaign
Healthy Students, Promising Futures (partners with HCA)
District-wide decisions and updated or new policies are often made locally by a school district’s administration team, the School Board, or both together. Contact information for a school district’s administration team and School Board will be on the district’s website.
What now?
You’re likely wondering what happens now. If you want more information specific to your child’s needs or 504 plan, message me - let’s chat!
I’d also love to hear any other questions that are floating around out there - I’d like to make this Q&A style post a regular thing, so…ask away!
Stay centered, friends,
Mischa
