Executive Summary
In comments to HHS, NHeLP urges the Secretary to reject Pennsylvania’s Section 1115 demonstration extension request to continue waiving the Institutions for Mental Diseases (IMD) exclusion. This letter emphasizes that while NHeLP is supportive of efforts to increase access to services for Medicaid beneficiaries with substance use disorders (SUD), the Secretary has no statutory authority to waive the exclusion, particularly to extend demonstrations with no particular experimental value. In addition, several policy reasons are given to underscore the need to prioritize other more effective efforts that pose less risk of subjecting beneficiaries to harmful institutionalization.
