The short answer
No federal or state certification exists for "EPSDT-compliant EHRs." EPSDT (Early and Periodic Screening, Diagnostic, and Treatment) is a Medicaid benefit requirement that applies to medical providers delivering well-child visits—pediatricians, primary care clinics, and Federally Qualified Health Centers. It is not a service framework used by pediatric home care agencies providing private duty nursing or skilled nursing.
If your question is about pediatric primary care practices, your EHR needs to handle growth percentile tracking, developmental screening prompts, and periodicity schedule documentation. No CMS or state Medicaid agency publishes a list of approved products by name.
What EPSDT actually requires
EPSDT is a comprehensive preventive care benefit for children under age 21 enrolled in Medicaid. The screening services must include five components: a comprehensive health and developmental history (assessing physical and mental health, as well as substance use disorders), an unclothed physical examination, appropriate immunizations, laboratory tests, and health education.
States determine their own periodicity schedule—the timeline of when children should receive screenings—but the schedule must follow reasonable standards of medical and dental practice. Most states have adopted the Bright Futures periodicity schedule developed by the American Academy of Pediatrics (AAP) or a modified version of it.
Developmental screening requirements
States are required to cover developmental and mental health screening as part of EPSDT screening services under Section 1905(r) and 42 CFR 441.56. The screening must include a comprehensive health and developmental history including assessment of physical and mental health development. The AAP and CDC recommend that all children be screened for developmental, behavioral, and social delays using a standardized screening tool during regular well-child visits at 9, 18, and 30 months.
A validated screening tool must test all four developmental areas: motor, language, cognitive, and social/emotional. Validity scores for the tool must be approximately 0.70 or above, with sensitivity and specificity scores also at approximately 0.70 or above.
Nearly all states reimburse Current Procedural Terminology (CPT) code 96110 for developmental screening. New York is the notable exception—it does not reimburse 96110 separately but recommends developmental screening as part of EPSDT well-child visits.
Growth percentile requirements
Use the WHO growth charts for all children from birth up to 2 years of age. The WHO growth standards for children younger than 2 years have been adapted for use in the United States.
The CDC recommends using CDC growth charts from ages 2 through 19 years so health care providers can track weight, stature, and body mass index (BMI) from childhood through age 19 years. The CDC growth charts are a national reference that represent how US children and teens grew primarily during the 1970s, 1980s and 1990s.
Lead screening and other mandatory tests
All children enrolled in Medicaid are required to receive blood lead screening tests at 12 and 24 months of age. This is a federal requirement that applies uniformly across all states.
States may not impose prior authorization requirements for EPSDT screening services under CMS's interpretation of the law.
How this differs by state
EPSDT requirements are federal, but implementation varies by state periodicity schedule, approved screening tools, reimbursement policies, and documentation requirements.
| State | Periodicity Schedule | Developmental Screening Ages | Autism Screening | CPT 96110 Reimbursement | Special Requirements | |-------|---------------------|------------------------------|------------------|------------------------|---------------------| | Mississippi | 3-5 days, birth to 1 month, 2, 4, 6, 9, 12, 15, 18, 24, 30 months, then annually ages 3-20 | 9, 18, 30 months | Not specified separately | Yes | Standardized tool required | | Texas | Modified AAP Bright Futures | 9, 18, 30 months | Not specified separately | Yes | New member checkup within 14 days of enrollment for newborns; within 90 days for all other eligible members | | New York | AAP Bright Futures | Recommended at well-child visits | Not specified separately | No—included in well-child visit | Blood lead test at 1, 2 years; ages 3-6 if not previously tested | | California | AAP Bright Futures | 9, 18, 30 months | Not specified separately | Yes—twice yearly for ages 0-5; PA required ages 6-20 | Approved tools: ASQ, ASQ-3, BDI-ST | | Arizona | AAP Bright Futures | 9, 18, 30 months | Required at 18 and 24 months | Yes | Explicit ASD screening requirement | | Arkansas | AAP Bright Futures | 9, 18, 30 months | Not specified separately | Yes | Developmental surveillance at every well-child visit |
What your EHR must handle
Your EHR needs to support the following capabilities, regardless of vendor:
Growth tracking: WHO charts from birth to 24 months, CDC charts from 2 to 20 years. The system must calculate and plot percentiles for weight, length/height, head circumference (under 36 months), and BMI (2 years and older).
Periodicity schedule prompts: The system should track each child's Medicaid eligibility and flag upcoming EPSDT visits based on your state's periodicity schedule. It should prompt for the required components at each visit age.
Developmental screening documentation: The system must allow documentation of standardized screening tool results at 9, 18, and 30 months (or your state's required ages). If your state requires a specific approved tool, the EHR should support that tool or allow structured data entry of results.
CPT code support: If your state reimburses CPT 96110, the system must support billing this code with appropriate frequency limits and age restrictions.
Lead screening tracking: The system should flag children who need blood lead tests at 12 and 24 months, and in some states, catch-up testing through age 6.
Immunization records: Integration with state immunization registries or manual documentation of all vaccines administered.
Comprehensive documentation: All five EPSDT components must be documentable: health and developmental history, unclothed physical exam findings, immunizations, lab tests, and health education provided.
State notification and reporting requirements
States must submit the annual Form CMS-416 and the state medical and dental periodicity schedules electronically to CMS not later than April 1 of the year following the end of the federal fiscal year being reported. This is a state-level reporting requirement.
What people commonly get wrong
Confusing EPSDT with home care: EPSDT is a medical benefit for screening services, not a service model for home care agencies. Pediatric home health agencies providing private duty nursing follow physician orders from EPSDT-participating providers and bill for nursing services, not EPSDT screenings.
Assuming any EHR is certified for EPSDT: No federal or state certification program exists for EPSDT-compliant EHRs. Meaningful Use and ONC Health IT Certification do not include EPSDT-specific criteria. You must verify that your chosen EHR system can document and bill the specific components your state requires.
Missing the periodicity schedule differences: Providers sometimes assume the AAP Bright Futures schedule applies uniformly. While most states use it, some have modified it significantly. Texas has its own modifications, and Mississippi specifies exact visit ages including a 3-5 day newborn visit.
Not documenting all five components: Without documentation of the nature of the visit and the components of the visit in the medical record, Medicaid will deem the visit incomplete or not having taken place. Each of the five required components must be documented: history, unclothed exam, immunizations, labs, and health education.
Billing developmental screening incorrectly: Some states have specific frequency limits, age restrictions, or prior authorization requirements for CPT 96110. California requires prior authorization for CPT 96110 for ages 6-20 effective November 10, 2020. New York does not reimburse it separately at all.
Using non-validated screening tools: Your developmental screening tool must meet validation criteria—validity, sensitivity, and specificity scores of approximately 0.70 or above. Informal checklists or non-standardized questionnaires do not meet the requirement.
The category mismatch
If you operate a pediatric home care agency—providing private duty nursing, skilled nursing, or waiver services—EPSDT requirements do not apply directly to your service delivery. You document care based on physician orders, state home health regulations, and your service authorization. The child's primary care provider handles EPSDT screenings.
Your EHR needs to track physician orders, nursing assessments, medication administration, and skilled interventions. Growth measurements and developmental observations you document support the care plan but are not EPSDT screenings.
If you operate a pediatric primary care practice billing Medicaid for well-child visits, you are subject to EPSDT requirements. Your EHR must support the documentation and billing described above.
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