California’s New Statewide Multi-Payer Fee Schedule For School Linked Service
/Adapted from information on the DHCS website.
The California Department of Health Care Services (DHCS) has recently introduced “draft guidance” on the new Statewide Multi-Payer Fee Schedule For School Linked Services. This new fee schedule will replace the cumbersome Local Education Agency Medi-Cal Billing Option Program (known as LEA BOP) and streamlines the processes while removing the complexities and constraints associated with the LEA BOP. The new fee schedule will benefit schools in many ways, such as increasing student access to behavioral health services, providing a flat fee-for-services method that provides 100% reimbursement, and expanding the program to both Medi-Cal enrolled and commercially insured students. Most importantly, the new fee schedule will provide a permanent funding source to sustain behavioral health services for students.
CA’s Children and Youth Behavioral Health Initiative (CYBHI)
The new DHCS Fee Schedule is part of the $4.6 billion established as part of the Budget Act of 2021. The CYBHI is a tremendous and ambitious investment in youth behavioral health and provides a multiyear, multi-department package of investments that supports behavioral health for all of California's children, youth, and their families. The primary focus of the CYBHI is to promote social and emotional well-being, prevent behavioral health challenges, and provide equitable, appropriate, timely, and accessible services for emerging and existing behavioral health needs (including mental health and substance use needs) for children and youth, ages 0-25.
Statewide Multi-Payer Fee Schedule For School Linked Services
The DHCS is wrapping up year three in its five-year planned implementation, with the focus currently on implementing the new statewide, multi-payer, school-linked fee schedule in schools across California. Over $1 billion in one-time funding was invested to develop the infrastructure and capacity of schools and school districts to meet the behavioral health needs of students, that can then be sustained through the reimbursable rates established in the CYBHI fee schedule.
Using a three-phased approach, DHCS launched Cohort 1 on January 1, 2024, with 47 Local Educational Agencies (LEAs). On February 16, 2024, DHCS released the Cohort 2 Statement of Interest Survey and Operational Readiness Application to LEAs and County Offices of Education (COEs). This application package and supporting documentation must be submitted via the Statement of Interest Survey to DHCS for approval by April 15, 2024, to be a part of Cohort 2, which is set to start July 1, 2024. The remaining LEAs may still apply for Cohort 3, planned to begin January 1, 2025.
The DHCS Statewide Multi-Payer School-Linked Fee Schedule establishes the rates at which Medi-Cal, commercial health plans, and disability insurers (collectively referred to as MCPs) must reimburse LEAs and school-linked providers for providing services to a student under the age of 26 at a school site, including on-campus, off-campus and mobile clinic locations. The Fee Schedule Scope of Service Rates and Codes Draft provides information and an overview of the Scope of Services, Codes, and Reimbursement Rates. For additional information on the fee schedule, please watch the introductory video.
The new fee schedule replaces the Local Education Agency Medi-Cal Billing Option Program (known as LEA BOP) and differs greatly in the following ways:
Increases student access by expanding the program to Medi-Cal enrolled and commercially insured students
Applies to multi-payers, including commercial health insurance
Services that are rendered under the fee schedule will not be subject to any cost-sharing (e.g., co-pays, deductibles)
Utilizes a flat fee for service methodology (100% reimbursement)
No cost settlement required
No obligation for LEAs to pay for non-federal services
Eases LEA administrative complexities and constraints
Streamlines processes and requirements
Removes the ‘Random Moment in Time Study’ requirement
Draft Guidance on the CYBHI Fee Schedule
DHCS recently released the Draft Guidance document (94 pages) and it is now available for public review and comments. The service categories are: (1) psychoeducation, (2) screening and assessment, (3) therapy, and (4) care coordination / case management (pp. 10 & 11).
Psychoeducation involves:
Assisting the child/family to identify strategies or treatment options
Wellness education and skill-building services
A variety of skill-building groups are included under wellness education and skill-building services, including education around mindfulness, de-escalation, and emotional regulation.
Screening and assessments includes helping identify students at risk for mental illness and/or substance use disorders, ensure that appropriate supports are provided to students across risk levels, and inform prevention and early intervention strategies.
Therapy and treatment services include several modes of service delivery such as crisis intervention, individual therapy (counseling), group therapy (counseling), and dyadic (parent and child) family counseling.
Care coordination / case management involves services intended to support and guide patients and families through.
Educational Frameworks and Other State Programs
In defining the scope of services for the CYBHI fee schedule, DHCS included educational frameworks for student behavioral health needs and includes reimbursable services that are mostly within MTSS and PBIS educational frameworks and other state programs (p. 13).
Multi-Tiered System of Supports (MTSS): According to the guidance, some Tier 1 universal supports, like prevention and anti-stigma campaigns, are not reimbursable under the fee schedule, but Tier 2 services that provide supplemental supports for students would be reimbursable, including services like skill-building groups and group counseling. Tier 3 services that provide intensified support would also be reimbursable, such as individual counseling (therapy), medication management, and Coordination of Services Teams (COST).
Positive Behavior Intervention and Supports (PBIS): Like MTSS, PBIS identifies and establishes three tiers of support needed for behavioral instruction ranging from universal (preventive screenings) to individual (assessment-based treatment plans). Reimbursable services under the fee schedule may include services that can be used to address student needs at various PBIS tiers (p. 13).
Community Schools: In 2023, California invested $4.1 billion to create community schools that take a “whole child” approach that increases support for student’s learning, health, and overall well-being by offering integrated student supports such as educational programs for before school, after school, summer school. Community schools engage students’ families and communities in greater access to physical and behavioral health services, and will therefore be eligible for the CYBHI fee schedule reimbursement (p. 14).
Special Education: The fee schedule shall be utilized to reimburse LEAs or providers for services required in an IEP; furthermore, the fee schedule cannot be used to supplant existing funding sources used to provide services to students with disabilities (p. 15).
Referrals: The fee schedule does not limit a school’s ability to refer students to care outside of the school setting. However, only services that are provided at a school or school-linked site are eligible for reimbursement through the fee schedule (pp. 15-16).
Consent: Existing parental consent or consent to treatment requirements are not changed by the fee schedule. California state law allows minors 12 years of age or older to consent to mental health treatment when clinically appropriate (p. 27).
Confidentiality: All medical records under the CYBHI are confidential; the release of information must continue to follow state law, FERPA, HIPAA, and Medi-Cal laws and regulations. Schools will be responsible for finding other funding sources (e.g., LCFF) to reimburse the fee schedule services if the student, parents, or legal guardians do not consent to release insurance information. Schools should provide parents / guardians with information about the CYBHI fee schedule and encourage them to consent to release insurance information (pp. 27-28).
Detailed Scope of Services
DHCS has recently released the Draft Guidance document, which provides a detailed list of services eligible for the fee schedule. With the exception of psychological testing and evaluation, school counselors are listed as eligible practitioners in nearly every eligible service. The following tables provide a list of the detailed services:
Table 1: Psychoeducation: detailed services - pages 35-46
Table 2: Screening and assessment: detailed services - pages 47-58
Table 3: Therapy and treatment services: detailed services - pages 59-66
Table 4: Case management and care coordination: detailed services - pages 66- 73
School-Linked Partnership and Capacity Grants
To support schools in implementing the CYBHI fee schedule, the DHCS will award $550M in one-time School-Linked Partnerships and Capacity Grant Funding for schools and colleges to build capacity, infrastructure, and partnerships needed. California public K-12 schools will receive about $400 million, and institutions of higher education will receive about $150 million.
DHCS has created a funding guidance overview to provide guidance to County Offices of Education (COEs) and Local Education Agencies (LEAs) about the permissible uses of funding for the school-linked partnership and capacity grants.
Each County Office of Education will determine the funding strategy and disseminate funds to school districts, charter schools, community-based organizations, and/or other implementing partners in the county. The intent of these funds is to support LEAs in implementing the CYBHI fee schedule. The School-Linked Partnership and Capacity Grants will focus on three main goals: fee schedule readiness, expanded access, and collaborative infrastructure.
Fee schedule readiness aims to increase the number of LEAs that meet operational readiness requirements such as Medi-Cal enrollment agreement, Medi-Cal information disclosure statements, general and professional liability insurance, and other mandatory program requirements.
Expanded access aims to increase the availability, equity, and range of behavioral health services in schools by building capacity and expanding services. This includes expanding the physical space required and providing sufficient staffing by hiring additional Pupil Personnel Services (PPS) credentialed practitioners (certificated) and/or Licensed behavioral health specialists (classified). LEAs may also contract with behavioral health practitioners, provider groups, community-based organizations, or county behavioral health departments to expand services.
Collaborative infrastructure aims to develop a collaborative infrastructure across LEAs, MCPs (Medi-Cal and commercial plans), and county behavioral health departments. Collaborative infrastructure includes defined policies and protocols for data collection, storing, and transmitting to the State’s Third Party Administrator (TPA) and establishing a billing infrastructure to file claims and the ability to receive payments.
Other DHCS Programs
Social-emotional learning environment (SEL): With involvement across all 58 California COEs in regular statewide collaborative learning sessions, SEL includes a broader effort to train teachers and school staff to identify mental health distress, provide emotional support, and crisis counseling.
Student Behavioral Health Incentive Program (SBHIP): SBHIP provides funding to incentivize Medi-Cal MCPs to partner with LEAs to increase access to behavioral health services in schools. These funds can be spent to enable LEAs to provide fee schedule services through increased workforce training and capacity or infrastructure for behavioral health care.
Mindfulness, Resilience, and Well-being Supports for Children, Youth, and Parents: To promote wellness and mindfulness programs to support teachers and students in TK12 schools, $65M has been allocated to each of the 58 County Offices of Education for wellness and resilience-building supports for children, youth, and partners.
Behavioral Health Virtual Services Platforms: The CYBHI will also offer Behavioral Health Virtual Services Platforms to all California residents, regardless of insurance coverage, web- and app-based platforms offering free one-on-one support with a live coach, a collection of multimedia resources, wellness exercises, and peer communities moderated by trained behavioral health professionals.
CalHOPE Schools: The CYBHI provides several programs available at no cost to all public schools in California, including Angst: Building Resilience; A Trusted Space: Redirecting Grief to Growth; and Stories of Hope: SHORTS. These resources can help reduce the stigma associated with an individual seeking support for their mental well-being, build supportive environments, and teach how to recognize the signs of mental stress and duress in colleagues, students, and family members.
Conclusion
The Children and Youth Behavioral Health Initiative (CYBHI) is a five-year, $4.6 billion initiative that is transforming the way California supports children, youth, and families. Built on a foundation of equity and accessibility, the CYBHI works to reimagine a more integrated, youth-centered system that meets the needs of all young people, particularly those who face the greatest systemic barriers to wellness. Tasked with the lofty goal of helping youth and families when, where, and in the way they need it most, the initiative’s efforts are created for and by young people and families to meet young people where they are – in schools, on college campuses, and other learning environments – and provide needed access to mental health and substance use services and supports.
