The Medicaid and CHIP Payment and Access Commission (MACPAC) produced a report to Congress on the oversight of Institutions of Mental Diseases (IMDs). “MACPAC serves as a non-partisan legislative branch agency and independent source of information for Medicaid and CHIP and are responsible for reporting to Congress.” Federal definition for IMD are a “hospital, nursing facility, or other institution of more than 16 beds that are primarily engaged in proving diagnosis, treatment, or care of persons with mental diseases.”

The Report to Congress on Oversight of Institutions for Mental Diseases seeks to identify and describe facilities designated as IMDs and summarize state licensure, certification or accreditation requirements and Medicaid clinical and quality stands for these facilities. In addition to outlining the history and regulations governing IMDs, the report provides estimates of the numbers of IMDs accepting Medicaid and the services these facilities offer and discusses how Medicaid agencies enforce standards for behavioral health facilities that may be considered IMDs.

IMDs are excluded from receiving Medicaid payments with two exception to this IMD exclusion, the first related to older adults and children and youth: an inpatient hospital services, nursing facility services, and intermediate care facility services for people 65 or older or an inpatient psychiatric hospital services for individuals under age 21 furnished by a psychiatric hospital, a general hospital with a psychiatric program or an accredited psychiatric facility (Psychiatric Residential Treatment Facility). The second being that a state can apply for a waiver through Medicaid 1115 demonstrations, a state plan option for pregnant women, and through managed care arrangements.

MACPAC developed a tool to identify facilities that could be considered IMDs. The Substance Abuse and Mental Health Services Administration (SAMSHA) reviewed those facilities and provided additional information on the facility characteristics. The report identified only facilities that accepted Medicaid in the seven selected states –California, Colorado, Florida, Massachusetts, New Jersey, Ohio, and Texas and the types of services offered. Some of the services offered included counseling services including group or individual therapy, supported employment and vocational rehabilitation, peer support services, housing services and supports, and outpatient treatment services. To read the entire report, click here.

The IMD issue has become more important to the child welfare world recently since some states are receiving mixed signals on whether or not meeting the new Quality Residential Treatment Program (QRTP) under the Families First Act may cause those facilities to be categorized as IMDs under the CMS standards. That would make those children in QRTPs potentially ineligible for any Medicaid coverage.

About the Author:

John Sciamanna is CWLA's Vice President of Public Policy.

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