CMS Announces Short-Term IMD Exclusion Waivers for Mental Illness

November 2018 ~

CMS announced on November 13, a new opportunity for states to seek short-term institutions for mental disease (IMDs) exclusion waivers, which would allow Medicaid to pay for inpatient mental health services for adults with serious mental illness (SMI) and children with serious emotional disturbance (SED).

In a letter, the agency states it will now consider Medicaid demonstration waivers covering short-term stays (around 30 days) for acute care provided in psychiatric hospitals or residential treatment centers. CMS emphasized, in the letter, the need for states to bolster early identification services, better integrate mental health and primary care, increase access to crisis services and expand the use of Certified Community Behavioral Health Clinics (CCBHCs).

Within the guidance included in the letter, CMS offers recommendations on how state Medicaid programs could better address the need for early identification and intervention of youth with SMI, including making more early behavioral health screening available under the Early and Periodic Screening, Diagnostic, and Treatment (EPSDT) benefit, development of referral networks to mental health providers, better data-sharing between non-specialized providers and mental health providers, and improved access to mental health services through schools, including screenings.

CMS also suggests that states explore screening for mental health disorders in primary care settings and supporting primary care providers (PCPs) and pediatricians to provide treatment and/or referrals for mental health services with the support of consultations with specialists and care coordinators. The agency also notes the need to build up the availability of intensive outpatient and crisis stabilization programs as a way to prevent frequent emergency room visits for individuals with mental illness as well as any criminal justice involvement.

CMS goes on to explain that the waiver demonstrations must provide a full continuum of care for individuals with mental illness. While residential treatment in IMDs may be included, the agency says states will be expected to improve community-based mental health care and must adhere to strict budget neutrality requirements, meaning that the demonstration cannot cost the federal government more than what it would have paid absent the demonstration.

Source(s): CMS Letter; CMS Press Release; HMA Weekly Roundup November 14, 2018; U.S. Department of Health & Human Services; The National Council of Behavioral Health; Health Leader’s Media; FierceHealthPayer;