DHS: CMS confirms Medicaid inmate exclusion does not apply to locked IRTS

CMS has affirmed that locked IRTS programs are not public institutions, so Medicaid billing is not barred by the inmate exclusion. The bulletin clarifies operational requirements for locked and unlocked IRTS settings, including client rights, court-order limits, restraint prohibitions, and documentation of civil commitment restrictions. Competency attainment services remain non-billable under the IRTS Medicaid benefit regardless of this determination.