Free to Client, Paid by Medicaid: Mission Safe Billing That Strengthens Care

Pregnancy medical clinics exist to remove barriers. You serve women in crisis, and you deliver medical care plus practical support. When leaders start discussing Medicaid billing, the first fear shows up fast. If we bill insurance, services stop being free.

That fear is based on a false assumption. Billing Medicaid does not turn your clinic into a pay to play model. Medicaid reimbursement flows from state and federal dollars. Your Medicaid patient typically pays no premium and no copay. Your clinic still treats every patient at no cost to her. You shift the payer source for eligible medical care from donors alone to the Medicaid program, while donors keep underwriting the parts of the mission Medicaid will never fund including patients who lack insurance altogether and your others services, like case management, material support, classes, fatherhood work, spiritual care, and crisis stabilization

Billing does something else leaders do not say out loud often enough. It strengthens legal defensibility and public credibility because Medicaid only pays for medically necessary services documented under recognized clinical standards and correct coding (ICD-10) and delivered by properly credentialed and privileged medical providers. That matters in a climate where pregnancy medical clinics face hostile narratives and aggressive legal scrutiny.

The deeper point is that billing medically necessary services, including controversial care such as progesterone therapy used in threatened miscarriage protocols (APR) regardless of the cause, validates your medical legitimacy. It shows that your services fit recognized diagnoses, medical necessity standards, documentation expectations, and insurer reimbursement rules. That reframes the conversation away from slogans and toward standard clinical governance.

FEAR: "We don't take government funds!"

ANSWER: Medicaid billing does not dictate scope of practice

Medicaid is a payer. It pays for covered services when your documentation supports medical necessity. It does not set your scope of practice.

Your scope is governed by three things.

1. State law and licensing rules.

2. Your medical director’s protocols, standing orders, and supervision structure.

3. Your board’s approved scope of services, risk tolerance, and quality oversight.

Medicaid will influence your workflow because billing requires discipline. It will not decide what you do. Your clinic decides what you do, then builds the compliance, documentation, and staffing to do it well.

Why billing strengthens care, not only revenue

It keeps care free to the client

You preserve the promise. No cost to her. Donors still matter, because donors fund everything Medicaid will not reimburse and for all the other patients, and they fund capacity building.

It improves clinical documentation and governance

Claims require a diagnosis, a documented assessment, a plan, and a clear link to medical necessity. Your charts get cleaner. Your informed consent gets tighter. Your QA and peer review gain real teeth.

It increases legal defensibility

In litigation and regulatory investigations, credibility wins. Credentialing, clean documentation, and consistent workflows help rebut claims that your clinic is not practicing legitimate healthcare.

It validates medically necessary services that draw controversy

When a clinic provides progesterone therapy under a threatened miscarriage protocol and bills within standard diagnosis and procedure frameworks, reimbursement becomes an external validator. It is not a moral argument. It is proof that the service fits mainstream reimbursement structures when documented correctly and clinically indicated.

A Medicaid only billing decision tree you can use right now

Path 1. No Medicaid billing yet

Choose this when leadership decides current risk, staffing, systems, or capacity do not support clean Medicaid claims. Care stays free for every patient. No claims submitted. Build readiness steps with assigned owners and dates.

Path 2. Medicaid only, selective services

Choose this when your clinic wants Medicaid validation and reimbursement without overwhelming staff. You bill Medicaid for a limited list of medically necessary services for Medicaid covered patients only. All other patients receive the same medical services free, with no insurance billing. This path fits many pregnancy medical clinics.

Path 3. Medicaid only, broader services

Choose this when you have stable staffing, a capable billing workflow, credentialed providers, strong documentation discipline, and leadership appetite for operational complexity. You bill Medicaid for most eligible medical services for Medicaid covered patients only. All other patients remain free, with no insurance billing.

Five factors to score before choosing a path

1. Mission guardrails. Non negotiables for free care, patient messaging, donor alignment.

2. Readiness. EHR, coding support, compliance program, credentialing, QA, documentation audit process.

3. Medicaid realities. Medicaid percentage, managed care plan landscape, continuity of coverage, prior authorization rules.

4. Net revenue. Reimbursement minus cost to collect, denial rate, staffing time, billing vendor fees if used.

5. Admin capacity. Who owns enrollment, claims, follow up, denials, audits, refund and recoupment workflow.

Medicaid only selective billing policy essentials

Billable list, non billable list

Billable list example categories for Medicaid covered patients only: pregnancy test encounter with evaluation, limited OB ultrasound when clinically indicated and properly documented, CLIA waived STI testing when ordered and documented, early prenatal type visits through your approved scope.

Add doula services where Medicaid reimbursement exists. As of October 2024, Medicaid reimburses community-based doula services in: Arizona, California, Colorado, Delaware, District of Columbia, Florida, Illinois, Kansas, Maryland, Massachusetts, Michigan, Minnesota, Missouri, Nevada, New Jersey, New York, Oklahoma, Oregon, Rhode Island, Virginia. Coverage rules vary by state, including who bills, number of covered visits, and credentialing requirements. Review your state Medicaid manual and managed care contract rules before adding this service line.

In Georgia, 50 Medicaid patients receiving early prenatal care up to but not including the anatomy scan can be reimbursed for $65,000 from Medicaid. You can do this with your current staff, updated standing orders, and a centrifuge and RNs who can draw labs at the initial visit. Labs are sent out for processing.

Non billable list for all patients: counseling ministry, parenting education, material assistance, mentoring, spiritual support, most case management activities unless reimbursable under a defined program. You can apply for various grants to support these programs.

Documentation rules tied to medical necessity

Each billed Medicaid encounter requires:

• Chief complaint and history

• Relevant exam elements

• Assessment with diagnosis code

• Plan tied to diagnosis

• Orders, results, and follow up plan

• Medical decision making appropriate to the service

Informed consent when required

Patient communication language

Your message stays clear. Your visit is free. If you have Medicaid coverage, we submit claims to Medicaid for eligible medical services. You will not receive a bill. If you do not have Medicaid, you receive the same medical services free. Donor giving funds care for uninsured patients and funds services Medicaid does not cover.

Board oversight step

Board approves the Medicaid only billing path, the selective billing policy, and receives a quarterly dashboard.

• Claims volume and reimbursement

• Denials and reasons

• Documentation audit results

• Patient complaints and resolutions

• Compliance issues and corrective actions

  
  

Where threatened miscarriage care fits in this framework

If your clinic provides progesterone therapy under a threatened miscarriage protocol (Abortion Pill Reversal), do not market a slogan. Practice within clinical governance.

• Use defined inclusion criteria.

• Document symptoms, exam, ultrasound findings when applicable, and clinical rationale.

• Use informed consent that states benefits, limits, alternatives, and follow up.

• Use correct diagnosis coding tied to the clinical picture.

• Keep peer review and QA tight.

When your claims reflect medically necessary care documented under recognized codes, reimbursement supports the narrative that your clinic delivers legitimate, regulated medical care.

The Bottom Line

Billing Medicaid is not mission drift. It is mission protection. You keep care free to the client. You add a stable revenue stream that supplements giving. You harden documentation, governance, and compliance. You gain external validation for medically necessary services, including services opponents label controversial.

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Shawn is a powerhouse in pregnancy center consulting, specializing in board training, policy development, grant writing, and more. Stay tuned for upcoming articles where she'll delve deeper into topics like grant writing, donor engagement, and conducting community health assessments. Visit https://zierkeconsulting.com/ to learn more