Monthly Medicaid Billing Checklist for Special Education in IL

When your district provides health-related services as part of students’ IEPs, 504s, or Health Plans, it’s important to ensure that your special education staff have a reliable monthly Medicaid billing checklist. This helps your special education team submit claims accurately and on time, allowing the district to receive reimbursement for eligible services.

So, what should you include in this checklist?

To assist Illinois special educators, our Embrace® Medicaid Success Team has prepared a list of essential requirements for successful Medicaid billing claim submission. More than 500 EmbraceDS® customers are already benefiting from having all these requirements built right into the software. As an EmbraceDS® customer, you also receive personalized guidance from our Medicaid Success Team and are notified if and when certain requirements are not met.

If you’re not yet an EmbraceDS® customer, you can still use this article to compile your own checklist and improve Medicaid billing compliance in your district—or reach out to our Sales Team to book an EmbraceDS® demo today.

1. Students must have a Medicaid Number

To submit a Medicaid claim, you’ll need the student’s Medicaid Number, also known in Illinois as the Recipient Identification Number (RIN).

Here's where and how school districts can obtain it:

• From the Student’s Medicaid Card. Parents or guardians may be able to provide the RIN directly from the child’s Medicaid card. The RIN is a 9-digit number usually found on the front of the card.
  
  
• Through the Illinois Medicaid Provider Portal. If your district is an approved Medicaid provider, staff with appropriate access can look up student RINs using the MEDI system (Medical Electronic Data Interchange) or EDW (Enterprise Data Warehouse).
  
  
• Through your Medicaid Billing Vendor. If your district uses a third-party Medicaid billing system like EmbraceDS®, RIN may be retrieved and stored securely in your Medicaid billing software. For EmbraceDS® clients, Medicaid eligibility is automatically checked, and RINs are automatically imported.
  
  
• From HFS (Healthcare and Family Services). Districts can also request RIN information directly from the Illinois Department of Healthcare and Family Services, provided that parental consent is on file and data-sharing agreements are in place.

2. Students should have parental consent to bill Medicaid

Parental consent is required before a district can bill Medicaid for services provided to a student. However, verbal consent is not sufficient. Consent must be signed by the student’s parent or legal guardian, and it may be obtained either with a physical signature or an electronic signature during the IEP process.

It is important that your staff informs parents/guardians that the school may seek reimbursement from Medicaid for certain services and use the Consent to Bill Medicaid form as part of the IEP paperwork. EmbraceDS® customers benefit from collecting electronic signatures fast and easy via our online Parent Portal.

Additionally, claims can only be submitted for dates of service on or after the date consent was signed. So, if a parent or a guardian does not provide written consent until April of a school year, the district may not bill for services provided prior to April.

Lastly, new consent must be obtained if a student transfers to a different district. For instance, if a student is moving from an elementary feeder district into an independently-established high school district, new consent will need to be obtained by the receiving district. EmbraceDS® automatically checks consent status and updates a dashboard with a list of students that are missing consent.

3. Students must have an active OT/PT prescription or Speech/Audiology referral on their Student Information Page

For students receiving Speech, Audiology, Physical Therapy (PT), or Occupational Therapy (OT) services, Medicaid requires documented medical necessity in the form of a prescription or referral before claims can be submitted for reimbursement. Submitting claims without a valid prescription or referral can result in claim denial or compliance issues during audits. 

How to identify whether you need a prescription or a referral:

• Occupational & Physical Therapy (OT/PT). These services must have an active prescription signed by a licensed physician or other qualified provider.
  
  
• Speech & Audiology Services. These require an active referral from a physician or licensed practitioner to establish medical necessity.

The active prescription or referral must be entered and tracked on the Student Information Page in your Medicaid billing program. In EmbraceDS® Medicaid billing system, coverage periods are carefully validated.

• If a prescription/referral is dated 02/02/2025-02/01/2026, and the student receives services on 02/02/2026 with no new prescription/referral to cover that date, the claim will not qualify for submission unless and until a new prescription/referral is added and provides coverage for that date of service.
  
  
• If a prescription/referral ends on 02/02/2026, and there is a gap between the end date and the next prescription start date (perhaps due to delayed IEP meeting date), any delivered services that fall in the gap will not qualify for submission and will not be exported from EmbraceDS®.
  
  
• Also, if a provider writes a prescription "for the (20XX/20XX) school year," staff can enter the start date of the prescription for the district's first day of that school year. If the provider does not specify that services are for the school year, districts must go by the date the prescription was signed. The EmbraceDS® Medicaid Success Team monitors these discrepancies and will notify your district of any necessary updates to ensure billing compliance.

4. All referring providers who sign off on prescriptions or referrals must have a valid NPI number and that number must be registered with IMPACT

IMPACT (Illinois Medicaid Program Advanced Cloud Technology) is the enrollment system used by the Illinois Department of Healthcare and Family Services (HFS). It serves as the official registry of Medicaid-approved providers in the state.

If a provider — such as a physician, nurse practitioner, or other qualified practitioner—writes a prescription or referral for Medicaid-billable services (e.g., OT, PT, speech therapy), their information must be:

• Tied to a valid National Provider Identifier (NPI). To search a provider by name or NPI in IMPACT, use the following link.
  
  
• Registered and active in the IMPACT system. Medicaid will not accept claims unless the referring provider has a valid NPI that is actively enrolled in IMPACT. If the NPI is missing or inactive, the claim may be rejected or delayed. The EmbraceDS® Team actively monitors for discrepancies and will alert your district if any providers aren’t registered.

5. Claims requiring Supervisor or Cosigner approval must be approved before claim submission

Certain Medicaid claims—such as those involving services delivered by support personnel like Physical Therapist Assistants (PTAs) — require supervisor or cosigner approval before they can be submitted. This is because Medicaid regulations mandate that only qualified providers can authorize and bill for services.

For instance, when a PTA delivers therapy, a licensed Physical Therapist must review and cosign the claim to:

1. Confirm the service was provided under their appropriate supervision.

2. Verify the service was clinically appropriate and aligned with the student’s treatment plan.

3. Ensure compliance with state licensure laws and Medicaid billing rules.

In EmbraceDS®, supervisor or cosigner approval can be provided in just a few clicks. To approve pending claims, supervisors can go to the top menu panel and select EmbraceDS® > Supervisor/Cosigner. Then, click on each student’s month hyperlink to view and approve (or deny) claims.

6. Providers who enter billable services must be listed in a billable PCG cost pool

In order to submit Medicaid claims through your Medicaid billing software, like EmbraceDS®, all providers who enter billable services must be included in a billable cost pool, specifically a PCG (Public Consulting Group) cost pool.

What is a PCG Cost Pool? A cost pool is a group of qualified staff members, such as Speech-Language Pathologists, OTs, PTs, nurses, psychologists, and others — who:

• are directly employed by the district or working under contract
  
  
• are involved in delivering Medicaid-eligible services
  
  
• are reported to PCG, the state’s Medicaid billing intermediary, for inclusion in quarterly Random Moment Time Studies (RMTS)

These cost pools are used by the state to determine how much reimbursement a district is eligible to receive for the services delivered by school-based providers.

Why providers must be in a Cost Pool:

• Only providers listed in a current, billable cost pool can have their submitted claims processed.
  
  
• If a provider is not in the cost pool, even if services are logged correctly, the claims will not qualify for submission and reimbursement.
  
  
• Being in the cost pool links the provider to the district’s financial reporting and ensures the time and services they provide are accounted for in Medicaid calculations.

It’s important to update cost pool rosters regularly to include new hires, contracted providers, or role changes. As an EmbraceDS® customer, you’ll get support from our Medicaid Success Team when/if your district encounters any cost pool errors, to ensure all eligible staff are listed in an active PCG cost pool.

7. Claims must fall within the timely filing window

Finally, to be eligible for reimbursement, claims must fall within the timely filing window for School-Based Health Services to be submitted to the state for reimbursement. 

Timely filing for IL schools is 180 days from the date of service. This means that if a claim is submitted after 180 days, it will be denied—even if all other billing requirements are met.

How to ensure that claims fall within the filing window:

• Encourage providers to log services promptly after delivery
• Use Medicaid billing tools (like a Reporting Dashboard in EmbraceDS®) to track upcoming filing deadlines
• Utilize EmbraceDS® accuracy reports to ensure accurate service delivery. These reports compare the prescribed services listed in the IEP to those delivered each month, highlighting staff who haven’t entered claims or students who should have claims but don’t

• Run regular reports to identify claims approaching the 180-day mark
  

If you don’t have internal expertise in Medicaid billing, you might want to consider working with a vendor like Embrace®, which can provide not only software but also personal assistance and help you manage the Medicaid billing process, reduce errors, and improve reimbursement rates.

Book the EmbraceDS® demo below!