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State Medicaid Testing Policies Compared with Federal CMS Requirement; Testing Rates

State State Follows Federal Requirement State Policy Is Formally Weaker % of kids receiving at least 1 test by age 2 (2014)
Via law, reg., contract? [A] Via manual, staff statement, website?
MA Univ. testing reg. 90%
DC Univ. testing reg. 86%
MN [B] EPSDT screening schedule & fact sheet 85%
IA Univ. testing reg. strongly encourages a test by age 2 (requires it by age 6) Staff reiterated CMS requirement 84%
NY Univ. testing reg. 84%
RI Univ. testing reg. 83%
IL [C] EPSDT provider manual 81%
GA EPSDT provider manual 80%
WI [D] Medicaid handbook, notes req. as federal 80%
MI [D] Health department screening guide, notes the req. as federal 79%
PA Provider bulletin with periodicity schedule; must test according to this to get paid 77%
NJ Univ. testing reg. 76%
HI Staff confirms state follows CMS mandate via Managed Care 75%
MD [E] Reg. 74%
TN Managed Care Contract 74%
LA Univ. testing reg. 68%
VA Reg. 68%
CA Reg. (with limited exceptions) 67%
U.S. 67%
DE Univ. testing law, for 12 mo. Provider manual, for 24 mo., but in section listing which tests “should” be done; state Medicaid staff deferred to lead program staff to clarify Acc. to recent statement by lead program staff: 24-month-olds required to be tested only if “high risk”; Medicaid enrollment is not an explicit risk factor 66%
KY 1998 EPSDT manual, incorporated by reference into reg. 66%
NE Public health division screening guide and website provide the CMS requirement as such; supported by state law State Medicaid rule only requires testing at 12 mo. (despite public health division’s statements) 65%
NH [E] Staff said federal requirement is told to providers 65%
FL Model Managed Care contract, covering almost all kids receiving EPSDT benefit 64%
MO State lead program rule EPSDT provider manual, notes req. as federal 63%
OH (State) rule, but stated as federal, not state, requirement 62%
MS Reg. 59%
SC Medicaid provider manual, notes req. as federal 59%
IN EPSDT provider manual (but parents need to give informed consent) 55%
WV EPSDT provider manual 52%
CO Staff indicates EPSDT rule should be interpreted as requiring this Directly stated in non-binding billing manual, as CMS req. 49%
KS Staff says Kansas requires this testing; providers are given a link to the federal EPSDT website/ manual; no state manual anymore 49%
NV EPSDT manual 41%
TX Periodicity schedule & Medicaid provider manual state CMS req. 39%
NM Staff statement 35%
UT Acc. to staff: State currently doesn’t mandate testing of Medicaid-enrolled children 22%
WA [E] Medicaid handbook states CMS req., since 2016 13%
AL EPSDT appendix to Medicaid provider manual Not available
AK Screening is required as appropriate for age & risk, but doctors have discretion on whether to test Not available
AZ CMS has approved targeted screening Not available
AR EPSDT provider manual Not available
CT In effect, required in universal testing reg. Not available
ID Reg. Not available
ME Law Not available
MT Testing is required but specific ages are only recommended Not available
NC Medicaid billing manual, as federal requirement; note staff said providers would have federal, not state, problem for not testing Not available
ND EPSDT provider manual, as federal req. Not available
OK Reg. Not available
OR “Coverage” manual directs providers to test at the federally required ages Not available
SD [F] Reg. Not available
VT Univ. testing reg. Not available
WY Medicaid provider manual Not available
Notes for Table 2
A – This column also includes the one state whose targeted testing policies have been approved by CMS: Arizona.

B – From 2003 to 2013, in contracts with managed care organizations, Minnesota’s Medicaid agency withheld part of the reimbursement for well-child visits if blood lead tests were not administered. Staff said this resulted in some screening rates exceeding 80% around 2013, and is probably a factor in the 85% rate shown here from 2014. Minnesota Department of Human Services staff, Personal communication, September 13, 2016; Minnesota Department of Health, “2015 Blood Lead Surveillance Report,” p. 11,

C – At least one Medicaid plan in Illinois provides a direct bonus payment if providers test a certain percentage of children for lead by 24 months of age. Illinois Department of Public Health, “Illinois Lead Program 2014 Annual Surveillance Report,” October 2015, p. 26,

D – Wisconsin issued Medicaid Provider Testing Reports to individual providers through 2011, and this had helped increase testing rates. See “Impact of State Policies on Testing Rates” within this section (IV) and Section V. Best Practices, below.

In 2014 at least, Michigan sent Medicaid Managed Care Plans information on their patients’ lead testing status to help boost compliance with the testing requirement. Scott, Robert, et al., “2014 Data Report on Childhood Lead Testing and Elevated Levels: Michigan,” Revised March 14, 2016, page 2,

E – The data is from 2014, before Maryland instituted universal testing of children born in 2015 and after (although the state had already required all children enrolled in Medicaid to be tested at 12 and 24 months prior to instituting universal testing); before New Hampshire began telling its providers about the federal requirement (which was spurred by the law passed in 2015 – see fn58); and before Washington State updated its lead testing policy.

Md. Code Regs.,; Miss. Code R. 23-223-1.6; New Hampshire Department of Health & Human Services staff, Telephone interview, June 24, 2016; Washington State Health Care Authority, “Washington Apple Health Early and Periodic Screening, Diagnosis and Treatment (EPSDT) Program Provider Guide,” April 1, 2016, p. 2,

F – South Dakota Department of Social Services staff also said via email dated June 9, 2016 that the state cannot require the test to be done.