By: Kimberly Lewis
Executive Summary
In comments to HHS, NHeLP urges the Secretary to reject California’s plan to renew its Institution for Mental Diseases (IMD) waiver for Medi-Cal beneficiaries with SUD. The comments emphasize concerns with flexibilities sought by the State to allow for longer stays at IMDs for both minors and adults. In addition, NHeLP’s comments demonstrate support for several new services, such as peer support services, but caution that the use of a Section 1115 waiver instead of a state plan amendment is inappropriate. Finally, NHeLP urges both California and HHS to require all counties to participate in the expanded SUD program.
