Recent policy shifts in California are significantly reshaping how foster youth access vital mental health services under Medi-Cal, the state’s Medicaid program. A key change eliminates the prior requirement for a formal mental health diagnosis for foster children and adolescents to receive Specialty Mental Health Services (SMHS). This update, driven by the understanding that trauma inherent in child welfare and juvenile justice involvement itself creates eligibility, aims to ensure timely and appropriate care for this vulnerable population.
Medical Necessity Redefined for Foster Youth Mental Health Support
The cornerstone of this reform is the revised definition of medical necessity. According to Welfare and Institutions Code (WIC) sections 14184.402(d) and (f)(1)(A), and further clarified in the California Department of Health Care Services (DHCS) Behavioral Health Information Notice (BHIN) 21-073, the experience of trauma due to child welfare or juvenile justice system involvement is now sufficient to establish medical necessity for children and youth under 21 to access SMHS. This pivotal change recognizes the profound impact of these experiences on mental health, moving beyond the need for a pre-existing diagnosis to initiate support.
To implement this crucial update, the California Department of Social Services (CDSS) issued All County Letter No. 24-35. This letter directly addresses county child welfare agencies (CWAs), juvenile probation departments (JPDs), Tribes with Title IV-E Agreements, and county mental health plans (MHPs). It clarifies that conducting a formal mental health screening to determine referral to MHPs is no longer mandatory.
Instead of preliminary screenings focused on diagnosis, CWAs and JPDs are now required to submit referrals to the appropriate MHPs for all children and youth within three business days of opening a child welfare case or juvenile probation placement. Ongoing referrals are also mandated as deemed necessary by the child and family team (CFT), informed by the Child Adolescent Needs and Strengths (CANS) tool, ensuring continuous assessment and access to services. This shift emphasizes proactive referral and ongoing evaluation, rather than relying on initial diagnostic screenings as gatekeepers to mental health care.
Medi-Cal for Kids & Teens: A Comprehensive EPSDT Benefit
The DHCS is committed to providing comprehensive early and periodic screenings, diagnostic, and treatment services to Medi-Cal beneficiaries under the age of 21 through the Early and Periodic Screening, Diagnostic, and Treatment (EPSDT) benefit, now known as Medi-Cal for Kids & Teens. Medi-Cal managed care plans (MCPs) play a vital role in delivering this benefit, ensuring early detection, prevention, and treatment of health issues for children.
The services included under Medi-Cal for Kids & Teens are extensive, encompassing:
- Screening services: Comprehensive health and development history assessments, physical examinations, necessary immunizations, laboratory tests, and crucial health education.
- Vision services: Complete diagnostic and treatment services for any identified vision issues.
- Dental services: Focus on pain and infection relief, restorative dental care, and proactive maintenance of overall dental health, including mandatory dental screenings/oral health assessments as part of periodic evaluations.
- Hearing services: Diagnosis and treatment of hearing impairments, potentially including the provision of hearing aids when medically necessary.
Beyond these core services, EPSDT further includes:
- Behavioral health treatment: Coverage for all medically necessary behavioral health services, consistent with guidance provided in APL 23-005, ensuring access to mental health support.
- Case management and care coordination: Support services to navigate and coordinate medically necessary EPSDT services effectively.
- Appointment assistance and transportation: Help with scheduling appointments and securing transportation to and from medical appointments for medically necessary EPSDT services, removing logistical barriers to care.
Streamlined Access through Screening and Transition Tools
To further enhance access, DHCS has developed standardized Cal-AIM Screening and Transition Tools for both adults and youth. These tools are designed for use by MHPs and MCPs to efficiently determine the most appropriate service delivery system for individuals seeking mental health services who are not currently receiving them. A standardized Transition of Care Tool also ensures seamless care coordination when members transition between service systems or add services from different systems to their existing treatment plans. These tools, implemented in January 2023, streamline the process of accessing mental health care within Medi-Cal.
“No Wrong Door” Policy: Ensuring Timely Mental Health Services
The DHCS’s Behavioral Health Information Notice No: 22-011 introduced the “No Wrong Door” policy. This policy is crucial in ensuring that Medi-Cal beneficiaries receive timely mental health services without unnecessary delays, regardless of where they initially seek care. It also prioritizes maintaining treatment relationships with trusted providers, preventing disruptions in care continuity. This policy underscores the commitment to barrier-free access to mental health support within the Medi-Cal system.
Conclusion
These policy advancements represent a significant step forward in ensuring foster youth in California receive the mental health support they need. By removing the diagnosis prerequisite and streamlining referral and screening processes, the state is actively working to improve access to timely, trauma-informed care for this vulnerable population. The focus on early intervention, comprehensive services through Medi-Cal for Kids & Teens, and barrier-free access policies like “No Wrong Door” collectively aim to foster better mental health outcomes for children and adolescents in foster care.
References
BHIN 22-011. (2022, March 31). Department of Health Care Services. Retrieved June 14, 2024, from https://www.dhcs.ca.gov/Documents/BHIN-22-011-No-Wrong-Door-for-Mental-Health-Services-Policy.pdf
California Advancing and Innovating Medi-Cal (CalAIM) OVERVIEW: Behavioral Health Payment Reform. (2022). Department of Health Care Services. Retrieved June 14, 2024, from
CalAIM Behavioral Health Initiative Frequently Asked Questions. (2024). DHCS. Retrieved June 14, 2024, from https://www.dhcs.ca.gov/Pages/CalAIM-BH-Initiative-FAQ-No-Wrong-Door-And-Co-Occurring-Treatment.aspx
Difficult Bi Design. (n.d.). The Promises and Possibilities of California’s Bifurcated Mental Health System. https://cachildrenstrust.org/wp-content/uploads/2024/05/CCT-Bifurcated-Promises-Possibilities.pdf
Frequently asked questions. (2024). DHCS. Retrieved June 14, 2024, from https://www.dhcs.ca.gov/Pages/Screening-and-Transition-of-Care-Tools-FAQ.aspx
Medi-Cal for Kids and Teens. (2024). DHCS. Retrieved June 5, 2024, from https://www.dhcs.ca.gov/services/Medi-Cal-For-Kids-and-Teens/Pages/home.aspx
Medi-cal’s foster care strategies. (2022, November). DHCS. Retrieved July 17, 2024, from https://www.dhcs.ca.gov/Documents/DHCS-Medi-Cal-Foster-Care-Strategies-11-22-2022.pdf
Medi-Cal Manual. (2018). For Intensive Care Coordination (ICC), Intensive Home Based Services (IHBS), and Therapeutic Foster Care (TFC) Services for Medi-Cal Beneficiaries. https://www.dhcs.ca.gov/Documents/ChildrensMHContentFlaggedForRemoval/Manuals/Medi-Cal_Manual_Third_Edition.pdf
Mental health and foster care. (2019, November 1). National Conference of State Legislatures. Retrieved July 15, 2024, from https://www.ncsl.org/human-services/mental-health-and-foster-care
MHSUDS Information Notice 18-059. (2018, December 17). Department of Health Care Services. Retrieved from https://www.dhcs.ca.gov/services/MH/Documents/Information%20Notices/IN_18-059_Continuity_of_Care/MHSUDS_Information_Notice_18-059_Continuity_of_Care.pdf
Myers, C., Lam, N. (n.d). Foster youth access to Medi-Cal specialty mental health services: A review of policies, procedures, and beneficiary-facing materials in the California counties with the largest foster care populations. National Health Law Program. https://healthlaw.org/wp-content/uploads/2023/09/CA-Foster-Youth-SMHS-Document-Review-Report.pdf
Provider Information. (2024). DHCS. Retrieved June 5, 2024, from https://www.dhcs.ca.gov/services/Medi-Cal-For-Kids-and-Teens/Pages/Provider-Information.aspx
Screening and Transition of Care Tools for Medi-Cal Mental Health Services. (2024). DHCS. Retrieved June 14, 2024, from https://www.dhcs.ca.gov/Pages/Screening-and-Transition-of-Care-Tools-for-Medi-Cal-Mental-Health-Services.aspx
