Eliminate Medicaid’s Institutions for Mental Disease exclusion
Recommendation
Congress should eliminate the Medicaid Institutions for Mental Disease (IMD) exclusion found at 42 U.S.C. § 1396d(a)(29)(b) and allow federal financial participation for inpatient mental health and substance use disorder (MH/SUD) treatment facilities without reducing expenditures for outpatient services within Medicaid.[1] A Medicaid state plan option should be established to cover care in specialized inpatient and residential settings, including IMDs, while also improving transitions and access to outpatient treatment.[2]
Background/summary
IMDs are facilities of 16 beds or more that are primarily engaged in diagnosing and treating MH/SUD.[3] These facilities can provide timely and comprehensive care to patients with MH/SUD needs. However, Medicaid beneficiaries experience significant barriers to their services due to CMS’s exclusion of those facilities from coverage for patients between the ages of 21-64.[3] Most Medicaid beneficiaries receive no federal reimbursement toward their care when treatment at an IMD is required.[3] No patient should be denied coverage due to the type of facility required for their care. Establishing Medicaid state plan options for residential care that include IMDs would be an incremental improvement. However, eliminating the IMD exclusion under Medicaid is vital for long-term improvements in access to care.[1][2]
citations
1. The Kennedy Forum. Recommendations of Congressman Patrick J. Kennedy to the President’s Commission on Combating Drug Addiction and the Opioid Crisis. Last Updated October 2017.
2. CEO Alliance for Mental Health. A Unified Vision for Transforming Mental Health and Substance Use Care. Last Updated August 2022.
3. National Association for Children’s Behavioral Health. WHAT IS AN IMD. Last Updated February 2, 2022.
4. Congressional Research Service. Medicaid’s Institutions for Mental Disease (IMD) Exclusion. Last Updated July 30, 2019.