Medicaid/CHIP News: Guidance on Providing EPSDT Services for Children in “Institutions for Mental Disease” (IMDs)

On June 20, the Centers for Medicare & Medicaid Services (CMS) released an Informational Bulletin that describes the requirements of section 12005 of the 21st Century Cures Act (the Cures Act) — “Providing EPSDT Services to Children in IMDs.” This section of the Cures Act requires Medicaid reimbursement for Early and Periodic Screening, Diagnostic, and Treatment (EPSDT) services for children under age 21 who are receiving inpatient psychiatric hospital services. Pursuant to 2012 guidance, states currently have the flexibility to cover all medically necessary services for children receiving inpatient psychiatric care, if the services were arranged to be provided as part of the patient’s plan of care. Hospitals and facilities are not obligated to enter into such arrangements, however, so children currently are not guaranteed access to the full range of EPSDT services. Pursuant to the June 20 Informational Bulletin, states are not required to submit revisions to their state plans to implement the new policy, but are expected to begin providing all EPSDT services to these children beginning January 1, 2019, as mandated by the Cures Act.