Executive Summary
In comments to HHS, NHeLP urges the Secretary to reject California’s Section 1115 demonstration extension request to waive 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 mental health conditions and 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, NHeLP provides several policy considerations regarding California’s proposals to efforts to building out a comprehensive continuum of care for beneficiaries with significant behavioral health needs.
