On November 20, NAMD submitted comments to a CMS Request for Information regarding future directions for the Center for Medicare and Medicaid Innovation (CMMI). NAMD calls for a stronger partnership between states and CMMI to promote further demonstration and alternative payment model alignment, and provides several specific issue areas where this partnership can be applied […]

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This NAMD letter responds to a supplemental proposed rule from the Substance Abuse and Mental Health Services Administration on the privacy requirements for substance use disorder (SUD) information (42 CFR Part 2). The letter underscores that separate privacy requirements for SUD information continue to prevent high quality, coordinated care for beneficiaries. It also makes recommendations […]

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This letter outlines Medicaid Directors’ ongoing concerns with CMS’s interpretation of the Medicaid managed care rule’s Institutions for Mental Diseases (IMD) provisions, and makes recommendations to enhance flexibility and streamline implementation of these provisions. Read full letter.  

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NAMD’s legislative and regulatory priority documents outline opportunities to modernize the federal rules governing Medicaid to ensure these comport with the realities and expectations for states to run high performing Medicaid programs. NAMD believes these modernizations – in federal statute and in federal regulation – can have a meaningful, positive impact for Medicaid enrollees. See […]

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NAMD Memo on the Medicaid IMD Exclusion

This memo provides background information for interested congressional staff on the IMD exclusion in light of the Center for Medicare and Medicaid Innovation’s (CMMI) recent decision not to extend the Medicaid Emergency Psychiatric Demonstration (MEPD). This document examines the context for the IMD exclusion; explores the available pathways for states to mitigate the IMD exclusion […]

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