Strengthening the Continuum: Actionable Strategies for Children with Co-occurring IDD and Behavioral Health Needs

CMS launched the State Medicaid & CHIP Toolkit for Children’s Behavioral Health Services and the Early and Periodic Screening, Diagnostic and Treatment (EPSDT)* Requirements this month, citing that “Improving access to high quality behavioral health treatment is among the Centers for Medicare & Medicaid Services’ (CMS) highest priorities and that CMS developed the behavioral health toolkit to support state Medicaid and CHIP agencies in ensuring that children and youth experiencing behavioral health conditions get the care they need. CMS further stated that “developing a behavioral health delivery system that accounts for children with specialized needs includes considerations for children with IDD.” “The toolkit provides essential reminders to states that children with IDD should have access to needed behavioral health services.”

The main body of the toolkit is divided into four main sections that include actionable state strategies and sub-strategies: 1) developing and supporting a behavioral health care delivery system that can meet a range of children’s needs; 2) promoting early intervention for children’s behavioral health conditions; 3) improving children’s access to behavioral health care through service coordination and integration; and 4) increasing the workforce capacity for children’s behavioral health services. When possible, CMS also included state examples within each strategy and sub-strategy to demonstrate various implementation options.

Some of the highlights include that providing an optimal continuum of care for children with intellectual disabilities (IDD) and co-occurring behavioral health needs requires a proactive, integrated approach that focuses on early intervention and active treatment.

To ensure these children thrive in their homes and communities, states can take immediate action by focusing on the following:

• Adapting Clinical Practices for Impact: While research continues to evolve, evidence suggests that children with mild-to-moderate IDD benefit significantly from behavioral therapies when simple, practical adaptations are made. States should encourage providers to utilize visual aids, shorter session lengths, and modified communication styles to make traditional therapies more accessible and effective.
• Maximizing Medicaid Authorities: To support children in the most integrated settings, states should look beyond the required EPSDT (Section 1905(a)) services. By leveraging 1915(c) HCBS waivers and 1915(i) State Plan authorities, states can provide robust wraparound supports—such as specialized habilitation and family training—that prevent institutionalization and promote stability.
• Enforcing Equitable Access: It is a critical reminder that a diagnosis of IDD is not a barrier to mental health care. Children with disabilities cannot be categorically excluded from behavioral health service coverage. States must ensure that their service arrays are inclusive, and that children receive the mental health supports they need, regardless of their primary disability.
• Focusing on Care Coordination: Covering care coordination and promoting the integration of physical and behavioral health can help minimize the potential for fragmentation or duplication of services and supports especially during the transition from pediatric to adult service systems.
• Building Workforce Capacity: States must address the recruitment and training of a behavioral health workforce as a statewide, cross-agency issue, as this “will ultimately impact the delivery and timeliness of quality services for Medicaid beneficiaries.” 

This Behavioral Health Toolkit represents an important step in supporting states to improve the provision and quality of behavioral health services for children and youth, as required under EPSDT. 

*EPSDT requirements at section 1905(a)(4)(B) and (r) of the Social Security Act (the Act), state that certain children and youth who are enrolled in Medicaid and under the age of 21 are entitled to coverage of health care, diagnostic services, treatment, and other measures described at section 1905(a) of the Act that are medically necessary to correct or ameliorate defects and physical and mental illness and conditions. While “behavioral health” is not an identified, stand-alone service within the Act, states are obligated to cover an array of medically necessary mental health and substance use disorder (SUD) services along the care continuum. EPSDT provisions specifically require states to include an assessment of both physical and mental health development in EPSDT-required screenings, as well as diagnostic and treatment services to correct or ameliorate illnesses and conditions identified by that screening.