NHeLP Comments on Oklahoma Section 1115 Institutions for Mental Disease (IMD) Waiver for Serious Mental Illness/Substance Use Disorder

Executive Summary

NHeLP urges the Secretary not to approve the requested waiver because 1) Oklahoma asks the Secretary to waive provisions of the Medicaid Act the Secretary does not have the authority to waive; 2) Oklahoma has not proposed a genuine experiment or novel approach; 3) Oklahoma’s proposal risks diverting funds away from community-based services, undermining decades of progress toward increased community-integration; and 4) the Secretary does not have authority to approve a Section 1115 waiver that would enable Qualified Residential Treatment Programs (QRTPs) to receive federal financial participation (FFP) for psychiatric treatment for individuals under 21 with SMI.

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