The American Rescue Plan passed in March included provisions providing states with new funding opportunities to leverage Medicaid to improve access to mental health services. Recent announcements by the Centers for Medicare & Medicaid Services (CMS) provide states with more information about how they can take advantage of the new opportunities.
Section 9817 Additional Support for Medicaid Home and Community-Based Services
The American Rescue Plan created a new nearly $12.6 billion federal funding opportunity for states that holds promise for additional resources to improve access to mental health services. As described in my colleague Edwin Park’s summary of the American Rescue Plan provisions, Section 9817, “Additional Support for Home and Community-Based Services during the COVID-19 Emergency,” provides states the option of receiving a 10 percentage point increase in their Medicaid matching rate for certain home and community-based services (HCBS) provided to Medicaid enrollees form April 1, 2021 until March 31, 2022. States may then use the funds from April 1, 2021 until March 31, 2024 to enhance, expand, or strength Medicaid HCBS provided the state meets certain requirements including that the funds supplement, not supplant existing state funding for such services.
In guidance on the provision released by CMS in May, CMS included certain mental health and substance use disorder services in its list of examples of allowable activities to “enhance, expand, or strengthen Medicaid HCBS” under Section 9817 of the American Rescue Plan (see, e.g., Appendix C). The guidance also listed certain school-based and rehabilitative services that may be eligible for the temporary increase under the provision (see, e.g., Appendix B).
This new HCBS funding opportunity could be especially important for children with significant mental health conditions. In this chapter of the Medicaid and CHIP Payment and Access Commission’s (MACPAC) June report to Congress, MACPAC found that while home and community-based services for children with significant mental health needs can help prevent institutional placement, such services are often unavailable or difficult to access. Additional support and investment in these services could go a long way in helping to better meet the needs of children with significant mental health needs.
According to the CMS guidance, states initially had 30 days to submit their initial spending plans with narratives. That deadline was extended by an additional 30 days to July 12th for states that requested an extension. Some states like Massachusetts have posted their spending plans and narratives online. Under the guidance, CMS has stated that it will publicly post summary information reported by states in their spending plans and narratives, however, the level of detail that will be provided by CMS and the timing of such posting remains unclear.
Alongside the Section 9817 HCBS funding opportunity, states may also want to explore coordinating such funding with the $3 billion in American Rescue Plan funding provided for SAMHSA block grants, including the $1.5 billion dispensed through the Community Mental Health Services Block Grant Program and the Substance Abuse Prevention and Treatment Block Grant Programs. State funding allocations for those awards can be found here and here.
Community-Based Mobile Crisis Intervention Services
In addition to Section 9817 of the American Rescue Plan providing additional federal funding support for HCBS, the American Rescue Plan also included a provision to allow state Medicaid programs the option to provide community-based mobile crisis interventions services to individuals experiencing mental health or substance use disorder crises for five years at an enhanced federal matching rate of 85 percent for the first three years.
The provision also provides $15 million in funding for planning grants to state Medicaid agencies to develop, prepare for, and implement qualifying community-based mobile crisis intervention services. According to a recent announcement by CMS regarding the state planning grant funding opportunity, planning grant funds can be used to support states’ assessments of their currents services, strengthen capacity and information systems, ensure that services can be accessed 24/7, provide behavioral health care training for multi-disciplinary teams, or to seek technical assistance to develop Medicaid state plan amendments or waiver requests to implement such programs.
How the needs of children will be addressed by mobile crisis interventions programs is an area where stakeholders may have an opportunity to weigh in and provide feedback as states explore such models. States like Connecticut and Massachusetts have mobile crisis intervention services specifically tailored to youth. Models such as these could serve as helpful examples as states consider the new state option and look to better address the mental health needs of children and youth.
According to CMS, letters of Intent to apply for state planning grants must be submitted by July 23, 2021 with final grant applications due August 31, 2021. States would then be able to use the awarded grant funds from September 2021 through September 2022. The full Notice of Funding Opportunity with key deadline and application information can be found here.
More to Be Done
While these actions are important first steps, much more will need to be done to meet the growing and specific mental health needs of children in the United States. In May, a number of national groups, including the Georgetown University Center for Children and Families, issued a set of Child and Adolescent Mental and Behavioral Health Principles identifying nine areas and corresponding opportunities to improve and enhance mental health services for children. Such principals could be the foundation for concrete and meaningful action to address the ongoing and longstanding unmet mental health needs of the nation’s children.