CMS Releases Guidance on New Medicaid Mobile Crisis Services Option

The Centers for Medicare & Medicaid Services kept busy over the holidays with the release of new guidance to states on the American Rescue Plan Act’s new Medicaid state option to provide qualifying community-based mobile crisis intervention services. 

As discussed here on Say Ahhh!, ARPA included a provision allowing state Medicaid programs to provide community-based mobile crisis interventions services to individuals experiencing mental health or substance use disorder crises and receive an enhanced federal matching rate of 85 percent for the first three years. The new option is available to states starting April 1, 2022 for a period of five years. If passed, the Build Back Better Act would go even further making the option permanent. 

In September, CMS announced the release of $15 million in authorized state planning grants to 20 state Medicaid agencies for the purposes of developing state plan amendments or waiver requests to provide coverage of mobile crisis services. A list of the 20 states that received planning grants can be found here. It is important to note however, that any state can take advantage of the new Medicaid mobile crisis services option, not just those that received a planning grant. 

Last month’s guidance from CMS provides additional information to state health officials on the new option. The guidance touches on a number of areas including: best practices, integration with the behavioral health crisis continuum of care, qualifying services and provider qualifications under the option, provider payment and delivery systems, increased matching rates and administrative claiming, data reporting, maintenance of effort requirements, and state plan amendment and waiver authorities. 

CMS also touches on children and youth in a number of areas within the guidance. 

As we’ve highlighted on the blog, addressing the mental and behavioral health needs of children is more important than ever given the ongoing youth mental health crisis. In discussing integration with the behavioral health crisis continuum of care within the guidance, CMS reiterates that under Medicaid’s Early and Periodic Screening, Diagnostic, and Treatment (EPSDT) benefit, states must provide coverage of all medically necessary services – including those for mental health and substance use disorder conditions – for eligible children under 21 that are included within the categories of mandatory and optional services listed in section 1905(a) of the Medicaid statute. This is required regardless of whether such services are covered under the state plan for adults. However, the guidance is silent on what CMS is doing to ensure compliance with this requirement.

CMS also highlights effective mobile crisis models under the guidance noting that partnerships with schools – including those that assist with connecting students to school-based mental health services, helping to ensure special needs such as those identified in individualized education plans are met, and providing psychoeducation training for school staff – are critical to helping to promote diversion. CMS also details that under the new ARPA mobile crisis services option, states must ensure that community-based mobile crisis intervention services teams maintain relationships with relevant community partners including pediatric providers.

While CMS does not go into specific detail on youth-focused mobile crisis models, the guidance notes that mobile crisis services, including those for children and youth, can incorporate a range of staffing models, including both professional and paraprofessional staff, crisis intervention specialists, therapists, case managers and trained peer and family support workers. As discussed on the blog, states like Connecticut and Massachusetts have mobile crisis intervention services specifically tailored to youth that states and others could look to as they develop and implement mobile crisis services that also meet the needs of children and youth.

Finally, in discussing broader administrative IT systems costs under the guidance, CMS notes that certain state Medicaid agency costs may be eligible for an enhanced administrative match including implementing text and chat technologies that beneficiaries, including youth, may be more comfortable using as part of the services offered by crisis call centers. 

To read more, the full CMS guidance can be found here

Anne Dwyer is an Associate Research Professor at the Georgetown University McCourt School of Public Policy’s Center for Children and Families.