Reminder: RMTS Participant List Certification Deadline – March 7th at 6 PM

The deadline for school districts to certify their Random Moment Time Study (RMTS) participant lists for the third quarter is March 7 at 6 PM. Missing this deadline could result in your district being excluded from the SHARS program for the federal fiscal year, leading to a loss of Medicaid reimbursements. Ensuring an accurate and compliant participant list is essential for maximizing SHARS funding and avoiding compliance issues.

Below, we’ll break down why the RMTS participant list matters, common mistakes to avoid, and how your district can stay compliant.

What Is the RMTS Participant List and Why Does It Matter?

The RMTS participant list is a position-based roster of staff members who provide School Health and Related Services (SHARS) to Medicaid-eligible students. The list should include roles that routinely deliver SHARS-covered services rather than listing specific individuals.

This list plays a crucial role in determining the Direct Medical Services Time Study Percentage, which is used in the SHARS cost report to allocate allowable costs for Medicaid reimbursement. If the list is inaccurate or includes ineligible staff, it can negatively impact the district’s reimbursements and compliance status.

Common Pitfalls to Avoid When Certifying Your RMTS Participant List

To prevent compliance issues and financial loss, districts should avoid these common mistakes when submitting their participant lists:

Focusing on names instead of roles – The RMTS list is position-driven, meaning you are listing job roles, not specific employees. If an SLP leaves mid-year, the position remains on the list, ensuring continuity without requiring immediate updates.
Including non-SHARS staff – Listing employees who do not routinely provide SHARS services lowers the Direct Medical Services Time Study Percentage, reducing reimbursements for all participating Texas districts.
Padding the list with unnecessary vacancies – Vacant positions should only be listed if the district has an active hiring process and intends to fill the role within the quarter. Otherwise, HHSC recommends removing vacant positions from the RMTS participant list.
Forgetting to update vendors – If your district partners with a Medicaid billing vendor, communicate any participant list changes so they can assist with cost reporting.

How Does an Inaccurate RMTS List Impact Your Cost Report?

Each quarter, a sample of RMTS participants is selected to answer three questions:

Who were you with?
What were you doing?
Why were you performing this activity?

If participants indicate they were performing non-SHARS activities, those responses lower the Direct Medical Services Time Study Percentage. Over time, this reduces SHARS reimbursements statewide, even if districts are still providing the same level of services.

Which Positions Should Be on the RMTS Participant List?

Only eligible positions actively providing SHARS services should be included. Below is a grouped list of roles that qualify:

Speech-Language Pathologists (SLPs), Interns, and Speech-Language Pathology Assistants (SLPAs)
Occupational Therapists (OTs) and Occupational Therapy Assistants (COTAs)
Physical Therapists (PTs) and Physical Therapy Assistants (LPTAs)
Registered Nurses (RNs), Vocational Nurses (LVNs), and Delegated Nursing Services
Audiologists and Audiology Assistants
School Psychologists (LSSPs)
Professional Counselors (LPCs)
Clinical Social Workers (LCSWs)
Marriage and Family Therapists (LMFTs)
Psychologists and Psychiatrists
Personal Care Service Providers (only those providing SHARS-covered activities)

For a complete list of eligible positions and compliance guidelines, refer to the Texas Medicaid Provider Procedures Manual (TMPPM).

Failure to Certify: What’s at Stake?

Missing the March 7 deadline could result in:

Loss of SHARS participation for the entire federal fiscal year
Loss of Medicaid reimbursements, including Cost Report settlement funds
Increased risk of audits and financial recoupments from HHSC

Final Reminder: Act Now to Meet the March 7 Deadline

To ensure compliance, districts should:

Review the RMTS participant list and confirm all positions perform SHARS services.
Remove any non-SHARS participants or unnecessary vacancies.
Certify the list in the STAIRS system before March 7 at 6 PM.

If you have questions about your RMTS participant list or need assistance with certification, reach out to your Onward Account Manager.

By ensuring your participant list is accurate and compliant, your district can maximize SHARS reimbursements while staying audit-ready.