The start of a new school year resets almost everything for a district: staff rosters change, service schedules are rebuilt, and new providers come on board. It is also the point where school based Medicaid claiming quietly comes back to life, and the Random Moment Time Study is at the center of it. For special education directors and school business managers, RMTS participation is not a box to check once and forget. It is an ongoing responsibility that runs all year, and the habits your staff build in the fall determine how much reimbursement your district captures. If RMTS has been running in the background while attention was elsewhere, now is the moment to make sure it is set up to succeed.
Why RMTS Decides Your Reimbursement
The Random Moment Time Study is a federally required methodology used to calculate the percentage of staff time that qualifies for Medicaid reimbursement. Instead of asking staff to log every minute, it uses statistical sampling. At random points during the school year, selected staff members receive a query asking what activity they were performing at that exact moment, and their responses build a statistically valid picture of how much time is spent on Medicaid reimbursable, health related work.
That percentage is not a technicality. It is the engine that drives your reimbursement, because it determines what share of your program costs can actually be claimed. Any local education agency seeking reimbursement through Administrative Activity Claiming or Direct Service Claiming must be included in an RMTS pool. In other words, participation is not optional if your district wants to claim, and the quality of that participation shapes the dollars that follow.
The 85% Threshold and What Happens Below It
MassHealth requires districts to maintain an 85% RMTS response rate, and that number carries real financial weight. When participation slips, the consequences are not limited to a single missed response. A low response rate can pull down your entire claiming pool, which means a handful of unanswered moments across the district can reduce reimbursement for everyone in that pool, not just the individuals who missed.
This is what makes RMTS non response one of the most costly and most preventable problems in school based Medicaid billing. Staff have only two school days to respond to a moment, and in the rush of the school day those windows close fast. A speech therapist between sessions, a nurse managing a full caseload, or an administrator buried in start of year logistics can miss a query simply because it arrived at a busy time. Multiply that across a district and the 85% threshold becomes harder to hold than it looks.
What Your District Should Do This Fall
The fall is the best window all year to get RMTS participation on solid footing, before missed moments start eating into the pool. A few priorities matter most.
First, confirm your pools are complete. Every staff member whose time should be captured needs to be included in the correct RMTS pool, because anyone left out is reimbursement left on the table. New hires and role changes from the start of the year are the most common gaps.
Second, make responding easy and routine. The biggest driver of a strong response rate is not effort but habit. Staff who know what a moment looks like, understand they have two school days to answer, and treat it as a quick task are far more likely to stay compliant than staff who are surprised by an unfamiliar email.
Third, build in reminders and monitoring. A district that only checks its response rate at the end of a quarter has already lost the moments it missed. Real time tracking lets you catch a slipping rate while there is still time to act.
How a Billing Partner Keeps You at 85%
This is precisely the work New England Medical Billing takes off a district’s plate. NEMB monitors RMTS participation and assists districts in putting in a change of status when one applies. A change of status allows a school to have a missed moment excuse if the provider had an approved absence for the whole duration of that moment, so a moment missed for a legitimate reason does not have to count against the district. Schools should monitor their moments and inform NEMB when a change of status is needed, which is a key part of staying above the 85% compliance regulation.
Beyond change of status support, NEMB actively monitors RMTS participation for its school district clients, tracking response rates, flagging staff who are at risk of falling behind, and providing the training and support needed to maintain the 85% threshold MassHealth requires. The team tracks your district’s submissions and can report exactly where you stand at any point in time, so you are never guessing about compliance until it is too late. With that visibility, a district can intervene with a specific staff member or building well before a quarter closes.
NEMB also brings the documentation side into alignment. The company integrates Financial and Special Education personnel in its approach, and its free proprietary software, SimpleNote, is built specifically for IEP service documentation. SimpleNote is fully HIPAA and FERPA compliant and customizable by state, which means the service notes that support your claims are captured cleanly alongside the time study data that validates them.
Set the Year Up Right
RMTS is not the kind of task that rewards last minute attention. The districts that consistently hit the 85% threshold are the ones that build good participation habits early, monitor throughout the year, and lean on a partner who handles the monitoring and change of status support so staff can stay focused on students. If your district is entering the new year unsure whether its RMTS participation is where it needs to be, this is the time to fix it. Learn more about NEMB’s school based Medicaid billing services, see how SimpleNote simplifies IEP documentation, or contact the team to request a free consultation and protect the reimbursement your district has already earned.
