Section 3.3.3 Service Delivery - Transitional Youth Age (page 8) 

It would be helpful to have some clarification on DMAS’s introduction of a new “transitional age range” of 16–25 with an added training requirement for providers to cover both youth and adult services. This framework is confusing and inconsistent with how DMAS itself currently defines youth services. 

In the current Mental Health Services Manual (Appendix A) defines youth services as covering individuals under 21. All other Medicaid programs serving youth also use this under-21 standard. Creating a new 16–25 category adds overlap and inconsistency: 

• It moves 16–20 year olds (who are already defined as youth) into a separate category that doesn’t match the existing framework.
• It adds extra training requirements for providers despite the youth/adult age boundary is already being clearly established, while increasing admin and staffing overhead costs.
• It creates confusion for families, providers, and MCOs because 16–20 year olds, given that they will now fall into two different definitions at the same time.

Obviously, the intent here is to support continuity of care as youth move into adulthood. But that can be achieved within the existing under-21 framework. Creating a separate 16–25 category is unnecessary, confusing, and directly contradicts DMAS’s own definition of youth services.