March 2024

School Health Services Program News

Our newsletter is a Department of Health Care Policy & Financing (HCPF) publication that provides information on the School Health Services (SHS) Program. The Colorado SHS Program is administered by HCPF in collaboration with the Colorado Department of Education (CDE). Providers participating in the program may receive federal matching funds for amounts spent in providing health services through the public schools to students who are receiving Health First Colorado (Colorado's Medicaid program) benefits.

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Program Components

FY 2023-24 Comprehensive Review Recap

Districts participating in the Colorado SHS Program undergo a comprehensive review at least once every three years. This review examines all areas of the SHS Program including validating financial records for the annual and Medicaid Administrative Claiming (MAC) quarterly cost reports, provider licensure for staff included on the direct service cost pool, and direct service claiming. 

The FY 2023-24 Comprehensive Reviews are now finalized. Thank you to those districts undergoing the review for your hard work and commitment to this process! Based on common findings for the Comprehensive Review, we would like to reiterate some important reminders for compliance below: 

  • Only report costs for the time the staff member was listed on the Staff Pool List (SPL) 
  • For example, if a staff member was listed on the SPL for only two out of the four quarters, only costs for the two quarters are able to be reported. 
  • Prior to populating the MAC or Annual Cost Report, ensure all federal funds are identified and stipends related to a provider’s primary job function are being included. 
  • Costs paid using federal funds or non-allowable costs should be reported under the ‘Compensation Federal Revenues/Non-Allowable Costs’ field in the Public Consulting Group (PCG) Claiming System 
  • Documentation for all costs and ratios must be retained by your district for at least 7 years from the last date of service. 
  • When reporting transportation costs, districts may not use district specific allocation methods to identify the portion of total district transportation costs associated with specialized transportation costs. Only Specialized transportation costs must be able to be discreetly identified with supporting documentation. 

Mid-Year Training Frequently Asked Questions (FAQs)

 Annual Cost Reporting FAQs 

Q: Are testing and evaluation materials for a student being evaluated for a medical plan of care an allowable expense on the annual cost report? 

A: Yes, testing and evaluation/assessment materials can be reported on the annual cost report under the appropriate service type for direct medical other costs.  

Q: Can longevity stipends be reported for staff on the annual cost report? 

A: Stipends relating to a staff member’s primary job function are allowable on the annual cost report. This includes longevity, retention, and hiring stipends. 

Q: Is the new Centers for Medicare and Medicaid Services (CMS) guidance being implemented next year?

A: The anticipated implementation for program changes as a result of the new CMS Guidance is FY 2025-26. Districts should continue to follow the current program rules until that time. The program changes will continue to be a topic at trainings leading up to the implementation.

Medicaid Administrative Claiming FAQs 

Q: If I had an underqualified individual on my SPL for a quarter, how would I report their financials? An underqualified individual is someone who appears on the SPL for the Direct Service Cost Pool and does not have the credentials to be in that position. One example is a Speech-Language Pathologist Assistant in your district who appears on the SPL as a Speech-Language Pathologist. 

A: If your district identified an individual that was underqualified for the job position, they were put in the SPL, they should be removed immediately and report zero costs. If that individual moved to the appropriate job category during the quarter, costs can be reported for that time spent on the SPL.  

Q: Do I need to put notes in the free form field on the quarterly cost report if I trigger a warning? 

A: When reviewing your quarterly financials and resolving any triggered warnings you are not required to enter any notes. To resolve the warnings on your quarterly cost report, use the drop-down box next to the explanation and select the appropriate option.  

Q: If my district reimburses me for attending an SHS Annual or Mid-Year training, can this be reported under staff, travel, and training on the MAC cost report? 

A: Yes, if your district reimburses your travel expenses for attending the SHS Annual or Mid-Year training and you are on the staff pool list, these costs can be reported under MAC other costs.  

Random Moment Time Study (RMTS) FAQs 

Q: Should I put a vacant position on my April – June SPL for someone who is not going to be hired until July? 

A: No, a vacancy should not be added. It is recommended as best practice not to add vacancies for SPL participants that will not be hired in two weeks. Vacant positions will be assigned survey moments that will not be answered which can negatively impact the statewide requirement of meeting statistical validity.  

Q: When should I mark my last day of school for my district? 

A: The last day of school should be marked as the last day regular staff are required to report to work across all school locations. The last day IS NOT the last day of school for students. 

CMS Guidance on School Based Services Reminder 

In accordance with the new comprehensive guide released on May 18th, 2023, HCPF is evaluating the current State Plan Amendment (SPA) to include any mandatory changes as a part of the guidance. If you haven’t already read the guide, please visit the following link: Delivering Services in School-Based Settings: A Comprehensive Guide to Medicaid Services and Administrative Claiming. 

Please remember the SHS Program will continue to operate according to current rules and regulations until the expected implementation of FY 2025-26. Below is the estimated timeline for the CMS Guidance.

PCG Claiming System Updates 

Locations feature will be removed 

PCG will remove the location feature during the summer months when there is no time study (July – September 2024). Updates by districts to the description field will not be erased when this change occurs.  

Certifying with vacancies 

Districts can now certify staff pool lists with vacant positions starting with the April – June 2024 quarter. When vacancies are added, they should be expected to be filled within 2 weeks of the start of the quarter. If there are any specific scenarios in which you are unsure a vacancy should be created, contact the PCG help desk for guidance

HCPF Updates

 SHS Program Stakeholder Forum

During the January 2024 stakeholder meeting, HCPF sought stakeholder input regarding CMS Comprehensive Guide requirements that will impact the Colorado SHS program. As mentioned during training, one of those areas is the RMTS. Stakeholders offered valuable feedback regarding the proposed length of the time study and number of moments. Stakeholder feedback will be taken into consideration as HCPF moves forward with seeking CMS approval and implementation of this new CMS requirement. Program changes based on the CMS Comprehensive Guide will be incorporated into future training sessions and the SHS program manual as we get closer to implementation. Until that time, the SHS program will operate according to the current program manual

Starting in Fiscal Year (FY) 2024-25, the Metro, Southeast, and Pikes Peak Regions will have stakeholder vacancies for current stakeholders whose terms will expire at the end of FY 2023-24. HCPF is also still searching for a stakeholder located in the Northwest Region. Stakeholder responsibilities include attending stakeholder meetings and monthly mentorship meetings, acting as representatives for districts in their regions, disseminating program information, and providing program feedback to CDE and HCPF. Details will be emailed in the coming weeks if you are interested in applying or reapplying to be a stakeholder. 

Mid-Year Training

The SHS program hosted three in person mid-year training sessions across the state and four virtual training sessions.  Thanks to everyone who attended.  Throughout the sessions we loved seeing that there were many examples of helpful program connections being formed and support being offered.  We appreciate the questions and conversations that took place during mid-year training, including about the National Provider Identifier (NPI) Ordering, Prescribing, and Referring (OPR) requirement. 

NPI OPR Requirement


HCPF welcomes questions and wants to hear from districts/BOCES while completing the NPI OPR requirement to add best practices and FAQs to the NPI OPR guide. Stakeholder representatives have been piloting this requirement since Oct. 2022 and HCPF will continue to build on stakeholder-developed best practices. For HCPF to provide the best support possible, please review the following:

  • Contact Olga at with general questions or feedback regarding the NPI OPR requirement.  
  • Utilize your stakeholder as a resource. HCPF is checking how districts/BOCES are progressing towards this requirement with their stakeholder representatives during stakeholder meetings.Thanks again to stakeholders for the best practices and guidance you helped develop and for your continued member district support. 
  • Gainwell should be contacted at 1-844-235-2387 to troubleshoot any issues regarding provider enrollment. 
  • After working with Gainwell, please email with an Application Training Number (ATN) if a provider is having continued difficulties completing the process.  
  • Answers to many questions may also be found in the resources contained on the Provider Enrollment and Provider Web Portal Quick Guides pages of the HCPF website.

Medicaid Eligibility Redeterminations Continues

Eligibility reviews for people with Health First Colorado (Colorado's Medicaid program) and Child Health Plan Plus (CHP+) continue after being paused for three years during the COVID-19 Public Health Emergency (PHE). 

Public Health Emergency (PHE) Unwind Reporting

Health Care Policy & Financing (HCPF) publishes renewal data reports and summary on the Continuous Coverage Unwind Data Reporting page. Information reported is point-in-time data about renewals as required by federal reporting requirements and does not include new members coming into the program or those who will take action during the 90-day reconsideration period. 

Members can return their renewal packet and any missing information to their county for processing within 90 days of losing coverage and ask for retroactive coverage if they experienced a gap. 

PHE Unwind Support

Please help us spread the word to Health First Colorado and CHP+ members to prepare for renewals by sharing the messaging our partner toolkits: Update Your Address and Take Action on Your Renewal. A new joint webpage,, also includes partner resources and information for those who may need to transition to other coverage. 

Member facing materials are available in English and Spanish and have been transcreated into the top 11 languages spoken by members: Amharic, Arabic, Burmese, Chinese, Dari, Pashto, Russian, Somali, Swahili, Ukrainian, and Vietnamese.

A few specific ways you can help:


Where to Find More Information

Partners can view Frequently Asked Questions (FAQs) about the end of the continuous coverage requirement and return to regular renewal processes and learn more about the renewal process to assist members who may need help.


Members with questions about the renewal process can be referred to the Health First Colorado’s renewal webpage available in English and Spanish


How to Stay Informed

The PHE Resource Center is updated regularly as reports are published and new information about the end of COVID-19 public health emergency and other COVID-19 policy evolves. Previous webinar presentations and recordings are also available.


Next Webinar Information

HCPF hosts quarterly webinars on the PHE Unwinding. These webinars are geared toward community partners such as advocacy organizations, providers, and community organizations who may provide other assistance to Health First Colorado or CHP+ members (housing, social services, etc). Presentations and recordings from previous PHE Unwinding webinars are posted in the PHE Resource Center.


When: April 24, 2024, 1 - 2:00 p.m. Mountain Time

Register in advance for this webinar.


Thank you for your collaboration to Keep Coloradans Covered. 

Colorado Department of Education Updates

Local Services Plan (LSP)

In Oct. 2020, CDE began transitioning health service categories within LSPs from the previous list of health categories to the current format. By July 1, 2025, all LSPs on file will use the updated health service categories, which are the same categories on the Reimbursement Spending Report to CDE. If you would like to switch your health service categories early, contact Omar to start this quick and easy process. 


This transition of health service categories pertains to the 2020-25 LSP cohort. If you are unsure what cohort you are in, find your district/BOCES on the cohort lists on the CDE School Health Services Program timeline page. 

Reimbursement Spending Report to CDE

Data from this report will be reviewed and returned as data flyers for districts/BOCES after annual training. Districts/BOCES who did not spend funds for FY 2022-23 will instead only receive the state-data flyer. Keep in mind that data flyers are getting an update and will look different from prior years. 

CDE reviews reports as they are submitted and may provide the district/BOCES with notes. A revision of the LSP on file may also be recommended. Please contact Omar if you have not received an email concerning your district/BOCES’ review. 

Parental Consents Forms

On May 18, 2023, a proposed rule to modify the Individuals with Disabilities Education Act (IDEA) Part B regulations requiring public agencies obtain parental consent prior to accessing public benefits was posted. A final action was scheduled for some time in Jan. 2024. As mentioned during mid-year training, CDE will review the final action once posted and will notify districts/BOCES of any program changes. Until then, parental consent should be collected according to your district/BOCES’ current policy. 


As a reminder, one-time parental consent prior to accessing a child’s public benefits for the first time is still a requirement under Family Education Rights Privacy Act (FERPA) and is unaffected by the proposed rule. Furthermore, these forms concern the disclosure of personally identifiable information (PII) and are not a consent form to bill Medicaid. A notice of the parent's rights under the Individuals with Disabilities Education Act (IDEA) must also be provided before accessing benefits and annually thereafter. If you are unfamiliar with your district/BOCES one-time consent forms or annual notification practices, speak with your district/BOCES legal team. 

Need to meet? 

If you would like 1:1 support on reimbursement spending, the Local Services Plan (LSP) or the reimbursement spending report, feel free to schedule a help session or email Omar Estrada.

All CDE School Health Services Program support documents, as well as links to LSP documents and reimbursement spending report, are on the CDE School Health Services website.

Key Dates

FY 2023-2024 Stakeholder Dates

April 11, 2024


All meetings will be via Zoom & In-Person

In person location:

303 E. 17th Ave, 11AB

Denver, CO 80203

9 a.m. – 12 p.m.

Quarterly Cost Report

April 1, 2024

Jan-March 2024 (JM24) cost report opens for district reporting.

April 26, 2024

JM24 cost report certification is due.

The School Health Services Program is a joint effort between the Colorado Department of Education and the Department of Health Care Policy & Financing.

If you have any suggestions for the newsletter, please email the School Health Services Administrator Olga Gintchin, SHS Program Assistant Tracy Gonzales or Public Consulting Group (PCG).

Additional SHS Program Contacts: 


School Health Services

Public Consulting Group - Claiming System

Colorado Department of Education

Health First Colorado