Ensure schools can receive youth peer support services
Recommendation
The Centers for Medicaid & Medicare Services (CMS) and Department of Education (DOE) should ensure schools are an eligible entity for receiving youth peer support services by issuing clarifying guidance and updating its administrative claiming guide to ensure youth peer support models are a permissible school-based service. CMS and the Substance Abuse and Mental Health Services Administration (SAMHSA) should offer learning collaboratives and technical assistance to states on peer support and billing best practices.
Background/summary
Peer support programming for youth and young people can effectively provide mental health support outside of traditional healthcare systems and can support culture change within healthcare systems. It is a trauma-informed practice recognized by SAMHSA that can help youth and young people manage their physical and mental health, build support networks, and engage in services.[1] Peer support is a priority outlined in President Biden’s 2022 Presidential Unity Agenda, and SAMHSA has issued National Model Standards for Peer Support Certification for local, state, federal, and tribal partners. [2][3]
Peer support is a Medicaid-covered service in over 45 states and reimbursable by the Veterans Administration. In 2013, CMS and SAMHSA issued an Informational Bulletin providing guidance to states on how to establish peer support services as a Medicaid benefit for children, youth, and young adults with “significant behavioral health conditions.” [4] Still, Medicaid funding for youth peer support is commonly funded under state Medicaid waivers, limiting available funding to a small percentage of high-need youth.[5] School-based health centers that are designated federally qualified health centers can also receive increased federal matching funds for providing Medicaid-approved mental health services like youth peer support but often express confusion about how to seek those funds. Similarly, school districts are often not familiar with how to properly bill Medicaid for peer support services – either provided by the school or by a peer hired by the school, community mental health center or provider, or other school-linked community organizations.[5] The Bipartisan Safer Communities Act invests in school-based services through Elementary and Secondary Education Act grants. However, it is unclear that youth peer support may be implemented with this funding.[6]
CMS and the DOE should ensure schools and states are aware that youth peer support programs may be implemented and expanded and should provide guidance to states on billing for peer services. CMS should update its administrative claiming guide with information about claiming and billing for youth peer support, with additional guidance on the topics of parental consent and alignment with provider requirements. CMS should also issue clarifying guidance that people under 18 years old can be provided peer support by another person under the age of 18. Guidance should discuss both Medicaid reimbursement pathways through managed care organizations and Medicaid fee-for-service reimbursement. CMS and SAMHSA should additionally offer learning collaboratives and technical assistance to states on peer support implementation and billing best practices and offer learning communities.[5]
citations
1. Davis, Kelly, Sriya Chilla, and Nghia Do. “Youth and Young Adult Peer Support Expanding Community-Driven Mental Health Resources.” Last Updated 2022.
2. The White House. 2022. “FACT SHEET: President Biden to Announce Strategy to Address Our National Mental Health Crisis, as Part of Unity Agenda in His First State of the Union.” The White House. Last Updated March 1, 2022.
3. U.S. Department of Health and Human Services, Substance Abuse and Mental Health Services Administration. “National Model Standards for Peer Support Certification.” Last Updated 2023.
4. Mann, Cindy, and Pamela Hyde. “Joint CMCS and SAMHSA Informational Bulletin: Coverage of Behavioral Health Services for Children, Youth, and Young Adults with Significant Mental Health Conditions.”Last Updated May 7, 2013.
5. Mental Health America, Center for Law and Social Policy, First Focus on Children, and Families USA. Memo to Perrie Briskin and Amy Banks, Department of Education, 2023. “Youth Peer Support as a Permissible School-Based Service.” Last Accessed March 28, 2023.
6. U.S. Department of Education, Office of Elementary & Secondary Education.“Legislation and Regulations.” Last Updated October 4, 2022.