Research suggests that one in seven children in the United States have a diagnosable mental health condition. But despite efforts to increase access to care through school-based mental health services, most youth with a mental health condition do not receive the treatment they need. Telehealth services, however, have the potential to increase access to school-based mental health treatment by reducing districts’ need for on-site personnel—of which there is a national shortage—without compromising the quality of care. Therefore, states should consider maintaining the telehealth flexibilities they enacted in response to the COVID-19 pandemic as a means to improve access to critical school-based mental health services for youth, even after the public health emergency ends.

The Centers for Medicare and Medicaid Services (CMS) provides states with considerable latitude in defining telehealth parameters and recently created a toolkit to provide guidance for states pursuing an expansion of telehealth services. States have historically imposed restrictions on telehealth; these include a requirement that first sessions for mental health treatment be delivered in person or that only audiovisual platforms may be used for the delivery of mental health services. However, these requirements have recently changed, as all 50 states and the District of Columbia have introduced various changes to increase flexibility in their telehealth policies—including telemental health—in response to the COVID-19 pandemic.    

While most states note that their relaxed regulations are temporary and will expire when the public health emergency ends, a few—including Idaho and Colorado—have already taken steps to make their new flexibility permanent. The increased flexibility includes eased licensing restrictions for providers, an expansion of the types of HIPAA-compliant platforms through which services can be delivered (e.g., telephone or Zoom), and the allowance of initial consultations via telehealth. Leaders in both states have noted that these changes have improved access to mental health services for their residents without compromising patients’ safety or privacy. Decisions to make temporary flexibilities permanent also align with findings from a forthcoming report on Medicaid reimbursement for school-based health services, which suggests that school district leaders see telehealth as essential to meeting students’ mental health needs. 

States interested in making temporary flexibilities permanent or further expanding telehealth may want to review the CMS State Medicaid & CHIP Telehealth Toolkit, which has recently been updated with considerations related to the COVID-19 pandemic and includes several practical planning tools. CMS has also clarified within the toolkit that expanding telehealth services—even permanently—does not necessarily require a state plan amendment if payments do not differ between telehealth and in-person services and if the existing state Medicaid plan does not require in-person services.   

For states that decide to maintain current flexibilities or further expand telehealth, health and education leaders should engage school-based mental health providers, youth, and their families to identify important lessons learned under the increased flexibility experienced during the pandemic. Doing so would constitute a crucial step in policy making: ensuring a presence and voice for vulnerable  populations who are often excluded from policy decisions that affect their own health, including youth of color, children with special health care needs, LGBTQ youth, and those living in rural areas.  

While the pandemic will eventually subside, increased access to telemental health services does not need to fade. States should take steps to permanently remove policy barriers wherever possible to expand telemedicine in schools and further shrink the gap in access to mental health treatment. 

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