The Bipartisan Safer Communities Act: Where Things Stand on the Medicaid and CHIP Provisions by Anne Dwyer On June 25, 2022, President Biden signed into law the Bipartisan Safer Communities Act (P.L. Provisions Covered in this Brief: 117-159).1 The Bipartisan Safer Communities Act included a number of provisions related to Medicaid Background and Status and the Children's Health Insurance Program (CHIP) XX Certified Community Behavioral Health Center including expanding the Certified Community Medicaid Demonstration Program Behavioral Health Clinic Medicaid demonstration program as well as mandated guidance, technical XX Medicaid and CHIP Telehealth Guidance assistance, and other resources and requirements XX Medicaid and School-Based Services: Guidance, related to telehealth, school-based Medicaid Technical Assistance Center, and Grants to States services, and Medicaid's Early and Periodic Screening, Diagnostic and Treatment benefit.2 XX EPSDT: State Implementation Review and Oversight Requirements With Medicaid (alongside CHIP) covering more than half of all children and serving as the single largest payer of behavioral health services in the US, timely and meaningful implementation of the Bipartisan Safer Communities Act provisions Medicaid remains important to advancing access to mental health care for children and individuals covered by and CHIP Medicaid and CHIP.3 This is especially important cover more given the ongoing youth mental health crisis and increasing rates of depression and anxiety among than half children.4 Now over a year into implementation, of all this issue brief provides background on the children Medicaid and CHIP provisions of the Bipartisan in the U.S. Safer Communities Act and an update of where things stand including where more action is still forthcoming. August 2023 CCF.GEORGETOWN.EDU the bipartisan safer communities act 1 Certified Community Behavioral Health Center Medicaid Demonstration Program Background: The Certified Community Behavioral Health Clinic (CCBHC) Nearly a quarter of CCBHC clients Medicaid demonstration was created in 2014 under the were children or adolescents (ranging Protecting Access to Medicare Act.5 The demonstration from 8 percent to 27 percent depending program provided select states with enhanced federal on the demonstration state), according to Medicaid matching funds (equivalent to a state's CHIP enhanced federal medical assistance percentage) for CCBHC a 2021 report by the U.S. Department of services provided to individuals covered by Medicaid. As part Health and Human Services examining of the demonstration, states are also required to establish the original eight demonstration states. prospective payment systems for Medicaid services delivered at CCBHCs and to ensure the clinics meet federal standards such as providing 24-hour crisis services and routine In order to participate in the expanded demonstration outpatient care, ensuring that services for children and youth program, interested states are required to apply for a planning are family-centered, youth-guided, and developmentally grant intended to support states in developing and certifying appropriate, and serving anyone who requests care for their CCBHCs and preparing an application to participate mental health or substance use, regardless of their ability in the four-year Medicaid demonstration.9 At the end of the to pay.6 Nearly a quarter of CCBHC clients were children or planning grant period, these states must submit applications adolescents (ranging from 8 percent to 27 percent depending to participate in the demonstration, including a description of on the state), according to a 2021 report by the U.S. the populations served through CCBHCs and the extent of Department of Health and Human Services (HHS) examining service needs. the original eight demonstration states.7 Initially limited to 8 states (and subsequently expanded to Status: In progress 10 states), the Bipartisan Safer Communities Act opened In March 2023, HHS announced that it awarded 15 states participation in the CCBHC Medicaid demonstration to all each with $1 million, one-year CCBHC planning grants in interested states under a phased-in approach under which support of state efforts to join the Medicaid-funded CCBHC 10 new states will be allowed to participate in the four-year demonstration program. Awardees included: Alabama, demonstration program every two years starting in 2024. Delaware, Georgia, Iowa, Kansas, Maine, Mississippi, The Bipartisan Safer Communities Act also provided $40 Montana, North Carolina, New Hampshire, New Mexico, million to the Secretary of HHS for purposes of carrying Ohio, Rhode Island, Vermont, and West Virginia.10 Up to 10 out the demonstration, including awarding planning grants of the 15 states that received planning grants will be eligible and providing technical assistance to states. Under the to participate in the CCBHC demonstration program and demonstration, each new demonstration state must establish receive enhanced federal Medicaid funding starting in 2024 a prospective payment system for Medicaid reimbursable when the first cohort of 10 states will be selected. For the CCBHC services with the state receiving enhanced federal demonstration period starting in 2024, current planning Medicaid funding for such services under their demonstration grant awardees must submit a proposal to participate in the period lasting four years. According to the Congressional CCBHC demonstration program no later than March 20, 2024. Budget Office, this national expansion is expected to provide over $8.5 billion in new federal Medicaid support over the next decade.8 August 2023 CCF.GEORGETOWN.EDU the bipartisan safer communities act 2 Up to ten states will then be selected to participate in the methods for CCBHCs via a State Plan Amendment or 1115 CCBHC demonstration starting on July 1, 2024 and receive waiver while continuing to receive their regular federal enhanced federal Medicaid matching dollars for the four- Medicaid match. The Substance Abuse and Mental Health year period. The Centers for Medicare & Medicaid Services Services Administration (SAMHSA), which helps lead the (CMS) has also noted that another round of planning grants is Medicaid demonstration program and issues separate expected to be made available to 15 additional states in fiscal expansion grants directly to CCBHCs to enhance or expand year 2024, for a second cohort of up to 10 states to join the capacity, tracks CCBHCs across the country. According to demonstration in 2025. SAMHSA, six states have CMS-approved payment methods for CCBHCs via SPAs or 1115 waivers including Kansas, Notably, separate from the demonstration program, state Minnesota, Missouri, Nevada, Oklahoma, and Texas.11 Medicaid programs may seek CMS-approval for payment Figure 1. Medicaid and CCBHCs Current or previous CCBHC Medicaid Demonstration States States receiving 2023 one-year CCBHC Medicaid Demonstration Planning Grant under Bipartisan Safer Communities Act States with CMS-approved payment method for CCBHCs via separate SPAs or 1115 waivers Source: U.S. Department of Health & Human Services, Substance Abuse and Mental Health Services Administration, "Certified Community Behavioral Health Clinics (CCBHCs)," accessed August 2023, https://www.samhsa.gov/certified-community-behavioral-health-clinics. August 2023 CCF.GEORGETOWN.EDU the bipartisan safer communities act 3 Medicaid and CHIP Telehealth Guidance Background: Status: Forthcoming States generally have broad flexibility to cover Medicaid and In 2020, CMS released the "State Medicaid & CHIP Telehealth CHIP services delivered via telehealth. During the COVID-19 Toolkit: Policy Considerations for States Expanding Use of public health emergency, many states expanded Medicaid Telehealth, COVID-19 Version" and a supplement in 2021.14 In telehealth policies especially as it relates to behavioral May 2023 HHS issued a Fact Sheet on telehealth flexibilities and mental health. A Kaiser Family Foundation survey of and unwinding of the public health emergency linking to state Medicaid programs found such services remain a top the resources and encouraging states "to continue to cover category with high telehealth utilization among Medicaid Medicaid and CHIP services delivered via telehealth."15 enrollees in state fiscal year 2022.12 The survey findings also However, the Secretary has yet to release guidance specific noted that many states reported permanently adopting some to the requirement under the Bipartisan Safer Communities or all of their COVID public health emergency-era Medicaid Act, which requires the telehealth guidance to be issued telehealth policy expansions for behavioral health but that not later than 18 months after enactment (i.e., December some states also reported limiting or adding guardrails to their 2023). According to a Medicaid and CHIP Mental Health and policies. A July 2023 report out of the HHS Office of Assistant Substance Use Disorder Action Plan released by CMS in July Secretary for Planning and Evaluation (ASPE) also found that 2023, the Administration plans to issue additional guidance telehealth delivery for behavioral health services continues to for states on the use of telehealth to provide services remain popular even as individuals return to in-person care for covered by Medicaid and CHIP by "the end of 2023," noting other types of services and noting the need for research into that states use of telehealth to provide services covered best practices.13 by Medicaid and CHIP have been shown to be particularly effective for improving access to mental health and substance The Bipartisan Safer Communities Act included a provision use disorder treatment.16 requiring HHS to provide technical assistance and issue guidance to states on improving access to telehealth for services covered under Medicaid and CHIP including: best practices from states that have used Medicaid waivers or other authorities to expand access to telehealth including during the COVID public health emergency; strategies to promote the delivery of accessible and culturally competent care via telehealth including addressing the needs of racial and ethnic minorities and individuals of different age groups such as children and young adults; best practices to support the delivery of covered services under Medicaid and CHIP via telehealth in schools, including specifically for the provision of mental health and substance use disorder services; and ? strategies for evaluating how the delivery of health services via telehealth affects quality, outcomes, and cost under Medicaid and CHIP. August 2023 CCF.GEORGETOWN.EDU the bipartisan safer communities act 4 Medicaid and School-Based Services: Guidance, Technical Assistance Center, and Grants to States Background: Status: Mixed (in progress and forthcoming) States and school districts can leverage Medicaid to In August of 2022, shortly after passage of the Bipartisan Safer provide health services and support mental health care for Communities Act, CMS released guidance via an informational students through a variety of mechanisms, including via bulletin on school-based services in Medicaid including school-based health centers, partnering with community information on funding, documentation and expanding services providers and through services provided via school-employed in school-based settings.20 The informational bulletin noted providers. When it comes to school-based services provided that the school setting provides a unique opportunity to enroll by providers employed by school districts, the federal eligible children in Medicaid and CHIP, furnish Medicaid- government opened up a new avenue for support when it covered services, including behavioral health services to reversed what is commonly known as the "free care rule" in children, and help children covered by Medicaid access the 2014. The free care rule reversal allowed states to receive services they need. As a follow up to the 2022 informational federal Medicaid reimbursement for Medicaid coverable bulletin, in May 2023, CMS released an updated Medicaid health services provided by school employees, including school claiming guide entitled, "Delivering Services in School- mental health services, for all students enrolled in Medicaid.17 Based Settings: A Comprehensive Guide to Medicaid Services Previous guidance limited reimbursement to services and Administrative Claiming" alongside informational bulletin included in a student's Individualized Education Plan (IEP) or introducing the guide."21 As the first comprehensive update Individualized Family Service Plan under the Individuals with in two decades, the updated guide clarifies and consolidates Disabilities Education Act. However, nearly a decade after policies put forth in 1997 technical assistance and 2003 the free care rule reversal, fewer than half of the states have administrative claiming guides while highlighting new flexibilities taken up the option to allow school districts to bill for health for billing and payment methodologies, best practices for services provided to students enrolled in Medicaid outside enrolling providers, and other claiming-related topics for of their IEPs.18 At the same time, the need for mental health Medicaid and CHIP services delivered in school-based settings. services has steadily increased; according to data from the Following the release of the updated Medicaid school-based Centers for Disease Control and Prevention, more than four in services claiming guide, in June 2023, CMS announced the 10 students felt persistently sad or hopeless in 2021.19 launch of the Medicaid and School Based Services Technical The Bipartisan Safer Communities Act included a number of Assistance Center (TAC), in coordination with the Department provisions related to Medicaid and school-based services. of Education, to assist in implementing the flexibilities and This includes guidance to state Medicaid agencies, local requirements of the Medicaid school-based services claiming educational agencies and school-based entities to support guide and further enhancing or expanding school-based the delivery of services to students covered by Medicaid and service programs.22 CHIP in school-based settings including updating school Medicaid claiming guides. The Act also required the Secretary of HHS, in consultation with the Secretary of Education, More than to establish a technical assistance center to assist state Medicaid agencies, local education agencies, and school- 4 in 10 students based entities on school Medicaid-related matters including resources for small and rural school districts. Finally, the felt persistently sad or Bipartisan Safer Communities Act authorized $50 million hopeless in 2021* for the Secretary to award grants to states for purposes of * Data from the Centers for Disease Control and Prevention. implementing, enhancing, or expanding access through school-based entities under Medicaid and CHIP. August 2023 CCF.GEORGETOWN.EDU the bipartisan safer communities act 5 The Medicaid Technical Assistance Center has a landing page updates and resources are still forthcoming including more on Medicaid.gov including some initial technical assistance in-depth guidance on various aspects of school-Medicaid materials such as sample State Plan Amendments, links to billing. The Secretary must also still award the $50 million in CMS policy papers and resources, and a CMS school-based grants to states made available under the Bipartisan Safer services inbox address and has started to offer a series Communities Act to implement, enhance, or expand access of webinars to support school-based services.23 However, through school-based entities under Medicaid and CHIP as noted in CMS's announcement of the TAC, additional which have yet to be issued. EPSDT: State Implementation Review and Oversight Requirements Background: every five years thereafter, the Secretary of HHS is required to review state implementation of the EPSDT benefit, identify Under Medicaid's Early and Periodic Screening, Diagnostic gaps and deficiencies with respect to state compliance, and Treatment (EPSDT) benefit, states are required to provide technical assistance to states to address such provide comprehensive services and furnish all coverable, gaps and deficiencies, and issue guidance to states on appropriate and medically necessary services need to correct the Medicaid coverage requirement for EPSDT services and ameliorate health conditions, including behavioral health including best practices for ensuring children have access conditions, if the service could be covered under the state to comprehensive health care services. In addition, within plan.24 In addition, states are also required to inform eligible six months of completing the state review activities, the individuals under the age of 21 of the availability of EPSDT Secretary is required to submit a report to Congress on the services. findings of the reviews including a description of actions Yet, children across the country continue to face long- taken by the Secretary or states as a result of the reviews standing unmet mental health needs. According to the and any additional actions the Secretary plans to take or Medicaid and CHIP Payment and Access Commission, that states are required to take as a result of the activities. only about half of all non-institutionalized youth enrolled Finally, the Bipartisan Safer Communities Act also requires in Medicaid or CHIP who experienced a major depressive the Government Accountability Office to conduct a study episode received mental health treatment in 2018.25 In and issue a report by June 2025 on state implementation addition, even though the COVID pandemic exacerbated of the EPSDT benefit with a focus on oversight of Medicaid mental health challenges among children, youth, and managed care plans and EPSDT, including potential their families,26 the rate of mental health services for recommendations to improve compliance and state oversight children covered by Medicaid and CHIP generally declined of managed care organizations as well as CMS oversight of throughout the public health emergency and remained below state Medicaid programs. pre-pandemic levels as of July 31, 2022 with approximately 25 percent fewer mental health services per 1,000 children under age 19 according to preliminary data from CMS.27 Status: Mixed (in progress and forthcoming) Unfortunately, monitoring the provision of EPSDT services to In August 2022, alongside the informational bulletin on determine whether the requirements of the Medicaid statute Medicaid school-based services, CMS also issued an are being met has been challenging due to data accuracy informational bulletin on "Leveraging Medicaid, CHIP, and and collection issues, low state compliance rates, and lack Other Federal Programs in the Delivery of Behavioral Health of reporting enforcement.28 Services for Children and Youth."29 The bulletin reiterates the requirement to provide all medically necessary care under The Bipartisan Safer Communities Act included a number EPSDT including prevention, screening, assessment and of provisions related to state implementation of EPSDT treatment for behavioral health conditions. It also provides a services and oversight. Most notably, by June 2024 and August 2023 CCF.GEORGETOWN.EDU the bipartisan safer communities act 6 bulleted list of existing EPSDT coverage obligations including the Centers for Medicaid and CHIP Services is "actively that determinations of medical necessity must be made engaged" with states on EPSDT compliance including as it on a case-by-case basis and hard, fixed, or arbitrary limits relates to medically necessary mental health care.30 However, on coverage for services are not permitted. The bulletin the Action Plan is silent on the status of the Bipartisan Safer also provides states and stakeholders with guidance and Community Act mandated state reviews or details of any examples on ways Medicaid and CHIP can be employed in additional forthcoming guidance, instead simply noting that the provision of mental health and substance use disorder the Act requires CMS to review states' compliance with services to children and youth focusing on four main areas: the Medicaid EPSDT benefit, provide technical assistance improving prevention, early identification and engagement to states, issue guidance on best practices, and provide a in treatment; increasing access to treatment across the report to Congress on its findings "by June of 2024." The continuum of care; expanding provider capacity; and Government Accountability Office has also yet to issue its increasing integration of behavioral health and primary care. report on implementation of the EPSDT benefit including Finally, the bulletin provides a list of existing Medicaid and Medicaid managed care. The report is due to Congress CHIP behavioral health-related guidance documents issued by June 2025 under the Act and may provide particularly over the years. important insights with over 80 percent of children covered by Medicaid enrolled in comprehensive managed care.31 According to the Medicaid and CHIP Mental Health and Substance Use Disorder Action Plan released in July 2023, Conclusion The Bipartisan Safer Communities Act included new federal resources and requirements related to the provision of mental health services for children and individuals covered by Medicaid and CHIP including expanding the CCBHC Medicaid demonstration program and including new requirements related to services delivered via telehealth, school-based services, and EPSDT services. While some of these initiatives are underway, others are still forthcoming with additional action required. Given the ongoing youth mental health crisis, timely and meaningful implementation of these provisions will remain important in furthering access to mental health care for children and individuals covered by Medicaid and CHIP. Acknowledgments This brief was written by Anne Dwyer of the Georgetown University Center for Children and Families. The author would like to thank Kelly Whitener, Natalie Lawson, Margaux Johnson-Green, Hannah Green, and Cathy Hope for their contributions to the report. Design and layout provided by Nancy Magill. The Georgetown University Center for Children and Families (CCF) is an independent, nonpartisan policy and research center based at the McCourt School of public policy. CCF conducts research, analyzes data, develops strategies, and offers solutions to improve the health of America's children and families, particularly those with low and moderate incomes. August 2023 CCF.GEORGETOWN.EDU the bipartisan safer communities act 7 Endnotes 1 For the statutory language of P.L. 117-159, see https://www.congress. 10 U.S. Department of Health & Human Services, Substance gov/bill/117th-congress/senate-bill/2938/text. Abuse and Mental Health Services Administration, "HHS Awards CCBHC Planning Grants to 15 States to Help Address Ongoing 2 Anne Dwyer, "Senate Releases Bipartisan Safer Communities Mental Health Crisis,' March 16, 2023, https://www.samhsa.gov/ Act, Includes Medicaid Mental Health Provisions," Say Ahhh! Blog, newsroom/press-announcements/20230316/hhs-awards-ccbhc- Georgetown University Center for Children and Families, June 23, 2022, planning-grants-15-states-address-ongoing-mental-health- https://ccf.georgetown.edu/2022/06/23/senate-releases-bipartisan-safer- crisis?utm_source=SAMHSA&utm_campaign=9e76ead62c-EMAIL_ communities-act-includes-medicaid-mental-health-provisions/. CAMPAIGN_2023_03_16_1602379&utm_medium=email&utm_term=0_- 3 Joan Alker and Aubrianna Osorio, "Child Uninsured Rate Could Rise 9e76ead62c- percent5BLIST_EMAIL_ID percent5D. Sharply if States Don't Proceed with Caution," Georgetown University 11 U.S. Department of Health & Human Services, Substance Abuse and Center for Children and Families, February 1, 2023, https://ccf. Mental Health Services Administration, "Certified Community Behavioral georgetown.edu/2023/02/01/child-uninsured-rate-could-rise-sharply-if- Health Clinics (CCBHCs)," accessed August 2023, https://www.samhsa. states-dont-take-care/; and Medicaid and CHIP Payment and Access gov/certified-community-behavioral-health-clinics. Commission, "Access to Behavioral Health Services for Children and Adolescents Covered by Medicaid and CHIP," June 2021, https:// 12 Madeline Guth, "Telehealth Delivery of Behavioral Health Care in www.macpac.gov/wp-content/uploads/2021/06/Chapter-3-Access-to- Medicaid: Findings from a Survey of State Medicaid Programs," Kaiser Behavioral-Health-Services-for-Children-and-Adolescents-Covered-by- Family Foundation, January 10, 2023, https://www.kff.org/medicaid/ Medicaid-and-CHIP.pdf. issue-brief/telehealth-delivery-of-behavioral-health-care-in-medicaid- findings-from-a-survey-of-state-medicaid-programs/. 4 American Academy of Pediatricians et al., "AAP-AACAP-CHA Declaration of a National Emergency in Child and Adolescent Mental 13 Peggy G. Chen et al., "State Medicaid Telehealth Coverage Policy Health," October 19, 2021, https://www.aap.org/en/advocacy/child-and- Decisions Since the COVID-19 Public Health Emergency," Office of the adolescent-healthy-mental-development/aap-aacap-cha-declaration- Assistant Secretary for Planning and Evaluation, July 12, 2023, https:// of-a-national-emergency-in-child-and-adolescent-mental-health/; and aspe.hhs.gov/reports/state-medicaid-telehealth. Aubrianna Osorio, "Research Update; Children's Anxiety and Depression 14 Centers for Medicare & Medicaid Services, "State Medicaid & CHIP on the Rise, Say Ahhh! Blog, Georgetown University Center for Children Telehealth Toolkit: Policy Considerations for States Expanding Use of and Families, March 24, 2022, https://ccf.georgetown.edu/2022/03/24/ Telehealth, COVID-19 Version," April 23, 2020, https://www.medicaid. research-update-childrens-anxiety-and-depression-on-the-rise/. gov/medicaid/benefits/downloads/medicaid-chip-telehealth-toolkit. 5 For the statutory language of the Protecting Access to Medicare Act of pdf; and Centers for Medicare & Medicaid Services, "State Medicaid & 2014, P.L. 113-93, see https://www.congress.gov/bill/113th-congress/ CHIP Telehealth Toolkit, Policy Considerations for States Expanding Use house-bill/4302; and Anne Dwyer, "HHS Announces New Planning Grants of Telehealth, COVID-19 Version: Supplement #1," December 6, 2021 for Medicaid-Funded Behavioral Health Clinic Demonstration," Say Ahhh! https://www.medicaid.gov/sites/default/files/2021-12/medicaid-chip- Blog, Georgetown University Center for Children and Families, October telehealth-toolkit-supplement1_0.pdf. 28, 2022, https://ccf.georgetown.edu/2022/10/28/hhs-announces- 15 U.S. Department of Health and Human Services, "HHS Fact Sheet: new-planning-grants-for-medicaid-funded-behavioral-health-clinic- Telehealth Flexibilities and Resources and the COVID-19 Public demonstration/. Health Emergency," May 10, 2023, https://www.hhs.gov/about/ 6 Medicaid.gov, "Section 223 Demonstration Program to Improve news/2023/05/10/hhs-fact-sheet-telehealth-flexibilities-resources-covid- Community Mental Health Services," accessed August 2023, https:// 19-public-health-emergency.html. www.medicaid.gov/medicaid/financial-management/section-223- 16 Center for Medicaid & CHIP Services, "Mental Health and Substance demonstration-program-improve-community-mental-health-services/ Use Disorder Action Plan," July 2023, https://www.medicaid.gov/ index.html. medicaid/benefits/downloads/cmcs-mntl-helth-substnce-disrdr-actn- 7 Joshua Breslau et al., "Interim Cost and Quality Findings From the plan.pdf. National Evaluation of the Certified Community Behavioral Health Clinic 17 Cindy Mann, "SMD# 14-006, Re: Medicaid Payment for Services Demonstration," U.S. Department of Health and Human Services, Provided without Charge (Free Care)," Centers for Medicare & Medicaid December 2021, https://aspe.hhs.gov/sites/default/files/documents/90c Services, December 15, 2014, https://www.medicaid.gov/federal-policy- 1c4d1646109391a938b6e25395dc5/ccbhc-interim-cost-quality-findings. guidance/downloads/smd-medicaid-payment-for-services-provided- pdf. without-charge-free-care.pdf. 8 Congressional Budget Office, "Estimated Budgetary Effects of S. 18 Healthy Students, Promising Futures, "Map: School Medicaid 2938, Bipartisan Safer Communities Act, as Amended by Senate Programs," Healthy Schools Campaign, accessed August 2023, https:// Amendment Number 5099," June 22, 2022, https://www.cbo.gov/system/ healthystudentspromisingfutures.org/map-school-medicaid-programs/. files/2022-06/S2938.pdf. 19 Centers for Disease Control and Prevention, "Youth Risk Behavior 9 U.S. Department of Health & Human Services, Substance Abuse and Survey: Data Summary & Trends Report, 2011-2021," February 13, Mental Health Services Administration, "Certified Community Behavioral 2023, https://www.cdc.gov/healthyyouth/data/yrbs/pdf/YRBS_Data- Health Clinic (CCBHC) – Improvement and Advancement Grants: Notice Summary-Trends_Report2023_508.pdf. See also American Academy of of Funding Opportunity (NOFO)," March 18, 2022, https://www.samhsa. Pediatricians et al., op cit. and Osorio, op cit. gov/grants/grant-announcements/sm-22-012. August 2023 CCF.GEORGETOWN.EDU the bipartisan safer communities act 8 20 Daniel Tsai, "CMCS Informational Bulletin, Information on School-Based 27 Centers for Medicare & Medicaid Services, "Medicaid and CHIP and Services in Medicaid: Funding, Documentation, and Expanding Services," the COVID-19 Public Health Emergency, Preliminary Medicaid and Center for Medicaid and CHIP Services, August 18, 2022, https://www. CHIP Data Snapshot, Services through July 31, 2022," https://www. medicaid.gov/federal-policy-guidance/downloads/sbscib081820222.pdf. medicaid.gov/sites/default/files/2023-02/covid-19-medicaid-data- snapshot-07312022.pdf (when comparing the PHE period of March 2020 21 Centers for Medicare & Medicaid Services, "Delivering Services in to July 2022 to the average values for months in years that predate the School-Based Settings: A Comprehensive Guide to Medicaid Services public health emergency). and Administrative Claiming," 2023, https://www.medicaid.gov/medicaid/ financial-management/downloads/sbs-guide-medicaid-services- 28 Georgetown University Center for Children and Families, op cit. and administrative-claiming.pdf; and Daniel Tsai, " Information on School- Daniel Young et al., "Children's Health Under Medicaid: A National Review Based Services in Medicaid: Policy Flexibilities and Guide on Coverage, of Early and Periodic Screening, Diagnostic, and Treatment Services, Billing, Reimbursement, Documentation and School-Based Administrative 2015-2019," National Health Law Program, June 29, 2021, https:// Claiming," Center for Medicaid and CHIP Services, August 18, 2023, healthlaw.org/resource/childrens-health-under-medicaid-a-national- https://www.medicaid.gov/sites/default/files/2023-08/cib051823.pdf. review-of-early-and-periodic-screening-diagnostic-and-treatment- services-2015-2019/. 22 Medicaid.gov, "CMS Announces Launch of New School-Based Services Technical Assistance Center," June 23, 2023, https://content. 29 Daniel Tsai, "CMCS Informational Bulletin, Leveraging Medicaid, CHIP, govdelivery.com/accounts/USCMSMEDICAID/bulletins/3616af8. and Other Federal Programs in the Delivery of Behavioral Health Services for Children and Youth," op cit. 23 Medicaid.gov, "Medicaid and School Based Services, Technical Assistance Materials," accessed August 2023, https://www.medicaid. Center for Medicaid & CHIP Services, "Mental Health and Substance 30 gov/resources-for-states/medicaid-state-technical-assistance/medicaid- Use Disorder Action Plan," op cit. and-school-based-services/technical-assistance-materials/index.html; 31 Medicaid and CHIP Payment and Access Commission, "MACStats: and FutureEd, "Webinar: Medicaid-School Based Services Technical Exhibit 30. Percentage of Medicaid Enrollees in Managed Care by Assistance Center, August 17, 2023," accessed August 2023, https:// State and Eligibility Group," December 2022, https://www.macpac.gov/ www.future-ed.org/event/webinar-medicaid-school-based-services- publication/percentage-of-medicaid-enrollees-in-managed-care-by-state- technical-assistance-center/. and-eligibility-group/ (as of fiscal year 2020). 24 Georgetown University Center for Children and Families, "EPSDT: A Primer on Medicaid's Pediatric Benefit," March 2017, https://ccf. georgetown.edu/wp-content/uploads/2016/03/EPSDT-fact-sheet.pdf; and Daniel Tsai, "CMCS Informational Bulletin, Leveraging Medicaid, CHIP, and Other Federal Programs in the Delivery of Behavioral Health Services for Children and Youth," Center for Medicaid and CHIP Services, August 18, 2022, https://www.medicaid.gov/federal-policy-guidance/downloads/ bhccib08182022.pdf. 25 Medicaid and CHIP Payment and Access Commission, op cit. 26 American Academy of Pediatricians et al., op cit. and Osorio, op cit. August 2023 CCF.GEORGETOWN.EDU the bipartisan safer communities act 9