In an issue brief dated April 18, 2022, the National Association of Medicaid Directors has highlighted that The IMD exclusion can make it challenging for state Medicaid programs to meet the behavioral health needs of their members. Specifically, there are challenges accessing inpatient services and contradictions with other policy goals.

NAMD suggests three opportunities for Federal action: repealing the IMD exclusion, creating exclusions for specific settings, and supporting states in developing robust community-based services and integrated behavioral healthcare.