January 16, 2023

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YLC Comments on the California Behavioral Health Community-Based Continuum

On January 13th, YLC submitted comments to the CA Department of Health Care Service’s proposal for CA Behavioral Health Community Based Continuum. Our comments focus on the impact of several important provisions for children and youth in foster care and juvenile justice systems including:

  1. Support for California’s proposal to utilize Medicaid funding for enrichment activities to promote health, wellness, and healing.
  2. Opposition to waiving the Institutions for Mental Disease–IMD–exclusion through Section 1115 because of the great risk to increased institutionalization for youth in foster care and juvenile justice on children and youth involved in the children, the prematurity of this proposal given recent California legislative changes, and the conflict with longstanding Medicaid law, the Family First Prevention Services Act, and state law that has aimed to reduce institutional care and ensure that when it is used, it is of high quality, short term, and focused on a transition to a less restrictive setting.
  3. Opposition to reversing state policy to allow unlimited lengths of stay for the first two years for young people in STRTPs that are IMDs.

You can read YLC’s full comments here.