CMS and ACF Issue Joint Guidance on Family-Focused Residential SUD Treatment

As required by the SUPPORT for Patients and Communities Act, CMS and the Administration for Children and Families (ACF) have issued comprehensive guidance reviewing the existing flexibilities within Medicaid to provide family-focused residential treatment for substance use disorders, and how the IV-E foster care program can support placing children with their parents in these programs. The Joint Informational Bulletin reviews a variety of Medicaid state plan authorities, benefit categories, and waivers that states may use to cover parents’ treatment, and how to coordinate Medicaid funding with IV-E and other federal funding to serve both parents and the children placed with them.

A section on the Medicaid Institutions for Mental Diseases (IMD) exclusion reiterates the policy reflected in Section 4390 of the State Medicaid Manual that beds in an SUD treatment facility that are used solely to accommodate the children of individuals who are being treated there are not counted against the 16-bed threshold for IMD determinations.  Children in family-focused residential SUD treatment facilities are not subject to the IMD exclusion.

A section on Room and Board notes that IV-E foster care payments may include the cost of room and board for a child residing in one of these facilities (under the congregate care provisions of the Family First Prevention Services Act), and may also pay for a parent’s room and board (under the MaryLee Allen Promoting Safe and Stable Families Program).

NACBH members are encouraged to review the guidance as you continue to talk with your state Medicaid and child welfare agencies about program and service development.  Please email Pat Johnston with any questions.