Family First Prevention Services Act Resource Center

Concerns Regarding IMD Classification

Our breakdown of concerns regarding the new FFPSA provision that might result in QRTPs being classified as IMDs.

Concerns regarding IMD classification


QRTP IMD Exclusion Update - 9/20/2019

The Centers for Medicare and Medicaid Services (CMS) has issued a technical clarification FAQ,  regarding the classification of Qualified Residential Treatment Programs (QRTP). The Q&A document identifies the statutory basis and definition of a QRTP, explains the Medicaid Institution for Mental Diseases (IMD) payment exclusion, discusses the intersection of a QRTP and the IMD exclusion, and explains how states may include QRTPs in a Section 1115 SMI/SED demonstration to ensure Medicaid coverage for services provided to Medicaid enrolled children residing in QRTPs.

Read the full FAQ here.


Concerns Regarding IMD Classification - 9/11/2019

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Under a new provision in the Family First Prevention Services Act (FFPSA), children who are eligible for Title IV-E foster care payments may be placed in a Qualified Residential Treatment Program (QRTP) in order to receive treatment for serious emotional or behavioral issues. As the first states begin to implement FFPSA next month, there have been concerns that the definition of a QRTP included in FFPSA would result in QRTPs being classified as an Institution for Mental Diseases (IMD), as defined by the Centers for Medicare and Medicaid Services (CMS).

If a QRTP is considered an IMD, states will be prohibited from using federal Medicaid for medical care provided to children in a QRTP with more than 16 beds.

There are states working to implement FFPSA in October and urgently need to resolve this issue to stay on track. This has become more urgent as Kentucky was recently notified by CMS that QRTPs would be considered IMDs. If the IMD issue would negatively impact children and youth served by your organization, contact your Congress members to ask them to work with CMS and the Administration for Children and Families (ACF) to issue guidance that clarifies that QRTPs are not subject to the IMD exclusion. Use this helpful FFPSA Advocacy Toolkit, which includes talking points, sample emails, FAQs, and more, created by Boys Town, St. Francis Ministries, and Children's Alliance of Kentucky, to advocate for your organization.

Please contact PublicPolicy@coanet.org if you have questions or comments regarding this issue.