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Stephanie Pellitt

, National Council for Behavioral Health

MACPAC Requests Public Comment on IMD Payment

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This week, the Medicaid and CHIP Payment and Access Commission (MACPAC) issued a request for comments from stakeholders on requirements, standards, and payments for institutions for mental disease (IMDs) under Medicaid. This announcement builds on recent moves by Congress and the Centers for Medicare and Medicaid Services (CMS) to provide opportunities for states to waive the IMD Medicaid payment exclusion for mental health and addiction services delivered in IMD settings. Specifically, the request comes in response to a provision from the SUPPORT Act that requires MACPAC to issue a report on IMDs and the services furnished by such providers. Providers interested in commenting have until May 31st at 5:30pm ET to submit comments.


MACPAC writes that it is particularly interested in learning more about state standards for IMDs and how those standards are enforced. The call for comments reflects the Commission’s discussion in its April 2019 meeting. Commissioners noted that under Medicaid, the concept of an IMD is better understood as a payment mechanism than a provider type. That is, many providers from freestanding psychiatric hospitals, residential mental health treatment facilities, and residential substance use disorder treatment facilities provide IMD services but may also provide other reimbursable Medicaid services.

The request calls for comment about the full breadth of services provided by IMDs and what outpatient services are available to patients who have been discharged from IMD settings. MACPAC requests information on how states certify, license, and accredit IMDs as well as what standards must be met by IMD providers to receive Medicaid payment. MACPAC also asks for a description of the breadth of IMDs receiving Medicaid payments and what funding mechanisms are used to pay IMDs.

Comments can be submitted until the May 31st, 2019 at 5:30pm ET deadline here. The report is due to Congress on January 1, 2020 and a draft will be discussed during the Commission’s September 2019 meeting.