NYSBHA provided the following comments on the extension of the MRT Waiver, an agreement between the federal Centers for Medicare and Medicaid Services (CMS) and New York State:

New York School Based Health Alliance (NYSBHA) supports New York’s effort to continue the existing Waiver and renew an agreement through March 2024.

Our comments are directed toward the need to focus funding to support children by including School-Based Health Centers as a valuable provider partner with the proposed Value-Driving Entities. As reported by the Children’s Clinical Advisory Committee and included in the First 1000 Days, the value proposition for children’s health services stems from promoting optimal child health across the life course, which will lead to lower long-term health care costs and utilization, principally by preventing chronic conditions in adulthood.

Integration of Primary Care and Behavioral Health and Crisis Services

One of the priority areas identified for continuation is primary care and behavioral health integration. In New York State, 75% of school-based health centers (SBHCs) have a mental health provider. Research has found this integrated model reduces barriers experienced in traditional mental health settings are overcome in school-based settings. Mental health counseling is repeatedly identified as the leading reason for visits by students. Adolescents are 10-21 times more likely to visit the SBHC for mental health services than a community health clinic or primary care practice. Studies have also found students who reported depression and past suicide attempts were more willing to use the SBHC for services.

Expansion of crisis services is another area identified for continuation in the waiver.

Mental health providers in SBHCs provide crisis services, which has led to decreased emergency department visits. These providers help address an urgent need for the pediatric population in which there are limited crisis intervention services available.

In New York City, schools are under court order to reduce removals to emergency departments. We support the use of DSRIP funds to support SBHCs to expand mental health services to respond to children in crisis.

Overall, SBHCs improve access to primary care services, one the measures included in the first MRT waiver and reported by Performing Provider Systems.


Alignment with First 1000 Days Recommendations

The First 1000 Days Preventive Pediatric Care Clinical Advisory Group states “Children – as a population – have relatively few acute healthcare needs, so there is limited opportunity for short-term savings through improved health outcomes. While investment in short term savings related to health outcomes should be explored, investment in a child’s optimal growth and development has the best potential to improve long-term health outcomes.”

Optimal child development and wellness are not adequately captured by traditional health care measures. The Clinical Advisory Group recommends the following measures:

  • Optimization of social-emotional health outcome through effective, integrated behavioral health services
  • Improved High School graduation rates
  • Decreased cardiovascular disease risk as youth enter adulthood
  • Decreased criminal justice and child welfare involvement

SBHCs are uniquely positioned to improve these measures. Studies have found that students who utilize SBHCs decrease school absences and tardiness and have a decline in school discipline referrals.

Medical providers in SBHCs monitor students with chronic illness, the commonly asthma. SBHC staff can provide education to students on their condition and how to manage it. Students with asthma who utilize SBHCs were found to have decreased hospitalization and improvements with medication adherence.


We appreciate the opportunity to comment on the extension of the MRT waiver.

We encourage the final waiver to include School-Based Health Centers as a partner in providing valuable services to children to have a positive long-term impact.

For additional information, please contact Sarah Murphy, NYSBHA Executive Director at nysbha@gmail.com