Category Archives: IMD Exclusion

CMS Issues New Guidance Aimed at Addressing Care for Mental Illness

Overview

On November 13, 2018 CMS (as mandated by Congress in the 21st Century cures Act) issued a State Medicaid Director Letter providing states with guidance on both: (1) existing authority for states to provide support for adults with serious mental illness (SMI) and/or children with a serious emotional disturbance (SED); and (2) a new demonstration opportunity  to permit states to offer care for certain individuals with serious mental illness residing in Institutions for Mental Disease (IMDs).… More

House Committee Advances Bill to Narrow IMD Exclusion for Opioids

We have written in the past about the strange quirk in Medicaid law that prohibits Medicaid from paying for medical services for individuals who are patients in an “institution for mental disease” – a facility that has more than 16 beds and that is “primarily engaged” in providing diagnosis, treatment and care to individuals with mental illness.  This prohibition – commonly known as the “IMD Exclusion” – is a vestige of the original Medicaid program,… More

Awaiting the new Medicaid Managed Care Rule

If the Office of Management and Budget’s website is to be believed, CMS will release the long-awaited Medicaid managed care rule in the coming weeks (our conversations with senior CMS officials indicated a similar timeline.)  The federal regulations governing Medicaid managed care have not been updated since 2002 and much has changed in the program since then, most notably managed care enrollment numbers: between 2002 and 2015 the percentage of managed care enrollees has grown from roughly 50% to nearly 80%.  … More