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MACPAC Requests Comments on the Medicaid IMD ADDITIONAL INFO ACT

Section 5012 of the SUPPORT for Patients and Communities Act (P.L. 115-271) requires the Medicaid and CHIP Payment and Access Commission (MACPAC) to conduct a study on institutions for mental diseases (IMDs) receiving Medicaid payment under fee for service or managed care. This section, known as the Medicaid IMD ADDITIONAL INFO Act, also requires MACPAC to seek input from a variety of stakeholders including the Centers for Medicare & Medicaid Services, the Substance Abuse and Mental Health Services Administration, state Medicaid officials, state mental health authorities, Medicaid beneficiary advocates, health care providers, and Medicaid managed care organizations.

As we develop our report to Congress, and to fulfill the requirement to seek input from stakeholders, MACPAC is interested in learning from interested parties about their views on the topics that the IMD ADDITIONAL INFO Act requires MACPAC to report on, including:

  • state requirements, including certification, licensure and accreditation applied to IMDs seeking Medicaid payment and how states determine if requirements have been met;
  • standards (e.g., quality standards, facility standards, and clinical standards) that IMD providers must meet in order to receive Medicaid payment and how the state determines if standards have been met;
  • a description of IMDs receiving Medicaid payment including the number of these facilities, and the types of services provided; and
  • a description of Medicaid funding authorities used to pay IMDs and any coverage limitations placed on the scope, duration or frequency of services provided in IMDs.

We welcome written comments on these areas and are particularly interested in learning about standards adopted by states to regulate facilities that are considered to be IMDs and how standards for these facilities are applied. Such facilities include freestanding psychiatric hospitals, residential mental health treatment facilities, and residential substance use disorder treatment facilities. In addition, we are interested in understanding the types of services provided in IMD facilities, as well as the availability of outpatient facilities that receive patients who have been discharged from IMD settings.

The final report is due to Congress on January 1, 2020; we will discuss a draft report at the Commission’s September 2019 meeting. This discussion will include the results of MACPAC’s ongoing analysis and what we learned from public comment received through this process.

We look forward to hearing from you and other stakeholders that you work with on these important issues. Please provide your response in writing to Erin McMullen at by 5:30 pm EDT on Friday, May 31, 2019.