NACHSA Supports IMD Fix to FFPSA

Introduced by Senators Burr (R-NC) and Feinstein (D-CA), the Ensuring Medicaid Continuity for Children in Foster Care Act of 2021 (S. 2869) would clarify that facilities meeting the new Qualified Residential Treatment Program (QRTP) requirements created by the Family First Prevention Services Act (FFPSA) should not be considered an Institution for Mental Disease (IMD) under Medicaid. Without the targeted carve out, facilities with more than 16 beds would be prohibited from drawing down Medicaid funds for any behavioral or physical health services provided to foster youth residing in such a facility. NACHSA sent this letter supporting the bill.

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