Medicaid and the State Children’s Health Insurance Program (CHIP) often cover physical and behavioral health services for children in foster care living in group homes and institutional settings, commonly referred to as congregate care.
The Family First Prevention Services Act (FFPSA) made significant reforms to the child welfare system, including placing restrictions on the use of federal funding for congregate care. Specifically, the FFPSA generally restricts the availability of Title IV-E foster care maintenance payments to 14 days unless the child is placed in a newly defined category of group homes called qualified residential treatment programs, which provide trauma-informed care to children with serious emotional and behavioral health disorders and meet other federal requirements. Depending on their size and other factors, qualified residential treatment programs may be considered institutions for mental diseases (IMD) for the purposes of Medicaid payment.
This fact sheet examines the intersection of the Medicaid IMD exclusion and the recent changes to Title IV-E funding. It describes qualified residential treatment programs and the IMD exclusion policy, including Centers for Medicare & Medicaid Services guidance highlighting relevant exemptions for QRTPs that are deemed IMDs. We then discuss how states are approaching FFPSA implementation and compliance with the IMD exclusion.
