Mental Health Parity: Progress and Implementation
As attention is gaining around parity and the implementation of the Mental Health Parity and Addiction Equality Act (MHPAEA), Beacon Health Options stands front and center in its efforts to help propel the law’s goals.
It’s been an ongoing process. One of the most recent efforts was Beacon’s submission of a letter on August 31 to the White House Mental Health and Substance Use Disorder Parity Task Force (Task Force), in response to a U.S. Department of Health & Human Services (HHS) call for comments from all stakeholders. In brief, that letter warned against instituting a “cookie-cutter” approach to behavioral health treatment in the effort to meet the laudable goal of comparability with medical/surgical services.
This multi-agency Task Force has the responsibility to identify and promote best practices for executive departments and federal and state agencies, “to better ensure compliance with and implementation of requirements related to mental health and substance use disorder parity, and determine areas that would benefit from further guidance.” The Task Force is expected to issue a report on October 31 with its findings and recommendations. It is possible HHS will issue additional FAQs in response to the report.
MHPAEA and the Triple Aim
According to a recent Health Affairs article, the largest share of health spending in this country is on mental disorders, and as such, more and better mental health/substance use disorder treatment is a must for our country to thrive. Beacon supports increased mental health/substance use disorder treatment, not only because of the societal and clinical imperative, but also from the business side; it allows Beacon to reach new patients who previously had no access to vital services. In this context, Beacon pursues the Institute for Healthcare Improvement’s Triple Aim for healthcare delivery:
- improving the patient experience of care (including quality and satisfaction);
- improving the health of populations; and
- reducing the per capita cost of health care.
There is no doubt that the MHPAEA’s goals of non-discrimination and comparability with medical/ surgical services are correct and laudable to improve all of health care for all people. However, as with any large piece of transformative legislation, much work still remains by regulators, payers, providers and public interest groups to help consumers understand their mental health/substance use disorder benefits and to ensure they receive the right type of individualized care. More specifically from a clinical and common sense perspective, mental health/substance use disorder treatment is not amenable to a cookie-cutter approach when comparing to medical/surgical services and treatment. Some of Beacon’s recommendations to the Task Force include the following points:
- Encourage recognition that differences exist between behavioral health and physical health. For example, utilization management occurs for both mental health/substance use and medical/surgical treatments because it is the right clinical approach in reviewing the medical necessity of a course of treatment or service for the patient’s condition. However, utilization management may be approached differently on the mental health/substance use disorder side due to the inherent nature of certain conditions and treatments, as opposed to a discriminatory intent. Beacon works to ensure that the best quality, evidence-based care is provided to consumers, which may look different depending on the illness or treatment. While Beacon agrees that the mind/body treatment is essential, ignoring the differences between diseases of the brain and other illnesses is ill-advised.
- With regard to disclosure of information to consumers, a user-friendly analysis of how health plans have achieved parity compliance should be adopted. A comprehensible approach would better serve consumers in their quest to ensure that mental health/substance use disorder (mental health/substance use disorder) practices are not discriminatory.
- Federal regulators should help prevent disparate interpretations among MHPAEA state regulatory agencies. The Task Force should impose uniform approaches to MHPAEA interpretation and enforcement.
Overall, Beacon is committed to parity compliance to help ensure individuals achieve healthier and more productive lives and will continue to work with policymakers and other stakeholders to do so. Together, we can.