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IMD Exclusion

The Medicaid program’s Institutions for Mental Diseases (IMD) exclusion discriminates against adult Medicaid beneficiaries by denying them access to specialized acute behavioral healthcare in psychiatric hospitals and residential treatment facilities. This provision is inconsistent with the principles of parity, hinders care, and contributes to the criminalization of mental illness.

Rising rates of suicide and overdoses highlight the need for improved access to acute mental health and addiction treatment that is provided in psychiatric hospitals and residential treatment facilities. Eliminating the IMD exclusion would give states flexibility to fund a full continuum of care for Medicaid beneficiaries struggling with serious mental illnesses and/or addiction.

NABH Advocacy Steps

NABH continues to advocate for Congress to repeal the IMD exclusion. At the same time, NABH is pursuing both legislative and regulatory solutions to reduce the burden of the IMD exclusion. These include:
  • Supporting legislation to waive the IMD exclusion for beneficiaries enrolled in Medicaid managed care plans.
  • Supporting legislation to allow state Medicaid programs to cover services in IMDs for MH and SUD treatment. Specifically, we support legislation from Rep. Mike Burgess, M.D. (R-Texas) and Sens. John Thune (R-S.D.), Marsha Blackburn (R-Tenn.), and Maggie Hassan (D-N.H.) to authorize state plan amendments to permanently waive the federal IMD exclusion for SUD services. (H.R. 3892 and S. 3098).
  • Supporting legislation and regulatory action to exempt qualified residential treatment programs from the IMD exclusion.
  • Educating key Members of Congress and their staff about the urgent need to expand this under-resourced segment of the behavioral healthcare continuum.

Policy Issues