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Letter ·

NAMD Requests Additional Flexibility on Qualified Residential Treatment Program Implementation

On July 8, 2021, NAMD sent a letter to the Centers for Medicare and Medicaid Services (CMS) requesting additional flexibilities on the implementation of Qualified Residential Treatment Programs (QRTPs), which are a type of setting that provides behavioral health services to young people in foster care.

The Family First Prevention Services Act, which intended to promote the deinstitutionalization of services for foster care youth, created a new type of behavioral health service setting called Qualified Residential Treatment Programs (QRTPs). In response, many states and providers began transitioning their foster youth services to meet the definition of a QRTP. However, the Centers for Medicare & Medicaid Services (CMS) then issued guidance strongly suggesting that QRTPs cannot have more than 16 beds due to Medicaid’s “institutions for mental diseases” (IMD) exclusion, creating access-to-care and budgetary issues for states.

NAMD sent a letter to Administrator Brooks-LaSure requesting that CMS revisit this interpretation and grant states additional flexibilities as they work to deinstitutionalize their foster care systems. Specifically, NAMD asked that CMS give states a minimum of five years to conduct IMD assessments of their QRTPs, provide greater deference to these state determinations, and allow states to exclude QRTPs from the IMD definition.

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