NHeLP Comments on New Mexico Centennial Care 2.0 SMI Amendment

Executive Summary

In this application, New Mexico seeks to waive the Institutes for Mental Disease (IMD) exclusion, implement High Fidelity Wraparound Services for an initially limited group of children and youth, institute a Graduate Medical Education Program, and establish vaccine coverage for limited beneficiary categories. For a variety of reasons, NHeLP suggests that the Secretary not approve this amendment request. In particular, NHeLP notes that the state has failed to provide evidence that many of these programs are genuine experiments. Further, HHS does not have the authroity to waive the IMD exclusion because the exclusion is found outside of 42 U.S.C. § 1396a. Additionally, waiving the IMD exclusion would undercut community-based mental health services. Finally, NHeLP notes that intensive care coordination services like High Fidelity Wraparound should be provided as a medically necessary service to all children and youth under the age of 21 through the state’s Early and Periodic Screening, Diagnosis and Treatment (EPSDT) mandate.

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