CMS made three big announcements yesterday, drawing attention to ways Medicaid and CHIP can support children’s health and well-being. The first two announcements are sub-regulatory guidance documents, essentially bringing together all of the existing state options and best practices on behavioral health and school-based health. Sub-regulatory guidance doesn’t include new policy, but rather aims to help states, managed care organizations, and providers meet health care needs more effectively. The third announcement is a notice of proposed rulemaking (NPRM) on health care quality data. This is an important development for America’s children and families. Of course, the public will have an opportunity to comment and we encourage you to do so. Here’s a quick summary of each of the three pieces, with more to come from my colleagues as we dig in.
This CMCS Informational Bulletin (CIB) reminds states and stakeholders that Medicaid and CHIP include behavioral health services and can be used alone or in tandem with other programs to promote high-quality care. The Department notes that COVID-19 has exacerbated the mental health crisis facing our children and teens as additional, pandemic-related health and economic stressors have disrupted their lives. The CIB aims to prevent the potentially lifelong consequences of unaddressed adverse childhood experiences (ACEs) and other behavioral health problems by providing information about Medicaid’s Early and Periodic Screening, Diagnostic and Treatment (EPSDT) benefit and other authorities to deliver effective prevention and treatment. My colleagues will have more to say about how this guidance can help promote mental health, especially for our youngest children. CMS plans to work with states to advance the policies outlined in the CIB and enforce compliance with EPSDT requirements.
This CIB emphasizes the importance of school-based Medicaid and CHIP services because schools are uniquely positioned to assist with enrollment in health coverage, delivery of some health services, and connections to other service providers as needed. The CIB outlines ways states can ease the administrative burdens of school-based services by providing a “checklist” of existing flexibilities and best practices to maximize Medicaid coverage for services furnished to children and teens in school. CMS plans to issue additional guidance on school-based services, specifically updated claiming and technical assistance guides, in light of the requirements in the Bipartisan Safer Communities Act (P.L. 117-159). Some parts of the CIB are pretty detailed, taking on complicated policy areas like the Free Care Rule, school-based services and managed care, and third party liability, but the overall message here is that CMS would like to see more and better delivery of Medicaid and CHIP services in school settings. My colleagues will have more to say about the details soon.
Readers of SayAhhh! know that reporting of quality data in Medicaid and CHIP has been optional so far, but that it will become mandatory in 2024. The NPRM details the reporting requirements that would standardize quality measures across Medicaid and CHIP nationally. In addition to laying out the requirements for the child core set, the NPRM describes the requirements for the behavioral health core set for adults and Medicaid health homes. Check out our Medicaid Learning Lab session on the child core set for background on quality measurement.
Though it will take a while to fully digest these three announcements, it’s exciting to see this amount of attention being focused on children’s health and well-being. Stay tuned for more details.