CMS Toolkit to Strengthen Child and Youth Behavioral Health: Implications and Strategies for States

On February 20, 2026, the Centers for Medicare and Medicaid Services (CMS) released a for state Medicaid and CHIP agencies to strengthen child and youth behavioral health consistent with Early and Periodic Screening, Diagnostic and Treatment (EPSDT) requirements and other available federal authorities. Under EPSDT, Medicaid-eligible children and youth under the age of 21 are entitled to all medically necessary preventive, diagnostic, and treatment services that are coverable under Medicaid, including services that are optional for adults. This includes appropriate mental health, substance use disorder (SUD), developmental, and specialty services for young people with emerging and identified behavioral health needs.  

Toolkit Overview

The toolkit is the latest in a series of CMS guidance on EPSDT and behavioral health, highlighting continued attention across the Biden and Trump administrations on the children’s behavioral health crisis. It is a follow-up to CMS’s 2024 EPSDT , which offers insight into states’ EPSDT obligations and outlines strategies for states to improve the services they provide to children and youth. The new toolkit reinforces the policies in the 2024 letter and provides an array of strategies and national best practices—as well as concrete examples—for states to leverage as they improve coverage of and access to behavioral health services for children and youth.  

Strategies for States to Strengthen Children’s Behavioral Health

The toolkit includes more than 20 strategies for state Medicaid and CHIP agencies to strengthen their children’s behavioral health systems consistent with EPSDT requirements. A complete list of the strategies in the toolkit is included in Table 1 below. Strategies in the toolkit are organized into four sections:

1. Developing and supporting a behavioral health care delivery system that can meet a range of children’s needs. In the toolkit, CMS outlines five categories of mental health and SUD services that states are required to cover under EPSDT when medically necessary: screening and assessment; early intervention services; community-based services at varying levels of intensity; urgent and crisis services; and inpatient care. The toolkit also provides examples of key behavioral health services states can cover under EPSDT and other Medicaid authorities—such as coordinated specialty care and wraparound programs for children and youth with complex needs—and illustrates how states are using bed registries and assessing utilization controls to ensure care is accessible and provided in the least restrictive setting.    
2. Promoting early intervention for children’s behavioral health conditions. A core tenant of EPSDT is to identify and address behavioral health conditions early. The toolkit includes a range of strategies to promote early intervention, such as encouraging states to pay for behavioral health screenings conducted by primary care providers and allowing services to be provided before a child has a formal behavioral health diagnosis. The toolkit also highlights the importance of collecting and using data to support early intervention. For example, some states are requiring providers to use standardized assessment tools such as the Child and Adolescent Needs and Strengths (CANS) to support clinical decision-making and better understand children’s behavioral health needs statewide.
3. Improving children’s access to behavioral health care through service coordination and integration. The toolkit reflects that children with behavioral health needs often engage with multiple systems, including health care, schools, the child welfare system, and the juvenile justice system. CMS highlights that care coordination and case management—including intensive care coordination for children and youth with complex needs—are fundamental to meeting states’ EPSDT obligations. The toolkit also highlights states that have leveraged integrated primary care and behavioral health models, such as the Collaborative Care Model, as well as states that have implemented a “single point of entry” to behavioral health services to reduce fragmentation or duplication across providers.
4. Increasing the workforce capacity for children’s behavioral health services. Finally, CMS reinforces that adequate provider networks are essential to fulfilling states’ EPSDT obligations and ensuring timely access to behavioral health care. The toolkit highlights how states are implementing strategies to bolster the behavioral health workforce, including through telehealth models like Project ECHO (Extension for Community Healthcare Outcomes). CMS also acknowledges the need for sufficient reimbursement rates to recruit and retain behavioral health providers, particularly for providers who work in rural areas and who serve youth with complex needs, such as those with a co-occurring mental health conditions and SUD. Notably, the toolkit also promotes reducing administrative barriers for behavioral health providers, including through policies such as “gold carding” where providers are exempted from prior authorization requirements because they have a strong track record of appropriate, evidence-based ordering, and expanding the types of practitioners that can deliver and be paid for behavioral health services.

Across all strategies, the toolkit reflects that there is no “one-size-fits-all” approach to a strong child and youth behavioral health system. States have flexibility in how they meet EPSDT requirements, and services and supports must be individualized to the unique needs of children and families.

State Implications

The new toolkit highlights CMS’s continued interest in supporting children’s behavioral health. Even amid ongoing federal changes and increased scrutiny on state Medicaid programs, there is a need to urgently and comprehensively respond to the ongoing behavioral health crisis. The toolkit—alongside recent EPSDT —reinforces that states have an obligation to cover and make accessible a robust continuum of behavioral health services that are tailored to children, youth, and families.

The toolkit provides states with strategies and specific state examples to drive improvements to the children’s behavioral health system consistent with EPSDT requirements. States can use the toolkit to support an assessment of their current children’s behavioral health system, identify gaps, and work to strengthen their Medicaid programs in line with national best practices.