A study published by the RAND Corporation, contracted by the HHS Assistant Secretary for Planning and Evaluation, includes a short term analysis of current implementation of the Mental Health Parity and Addiction Equity Act. The study focuses on two issues in the current regulations, non quantitative treatment limitations and scope of service. RAND convened a panel of experts, a panel of industry representatives, and Oregon insurance regulators to discuss the criteria that should be considered for parity implementation in the non quantitative treatment limitations. To determine the impact of applying parity to scope of service, focusing on various levels of coverage for intermediate services, RAND did an analysis of 2008 utilization data from Market Scan Health Benefits Database.
Some interesting findings in the 45 page report include:
- Special issues were identified for managed behavioral health organizations because of their unique situation of not having access to the NQTL criteria, processes and procedures for medical services.
- Industry reps gave examples of some uncovered services due to lack of medical necessity: ABA treatment for autism (educational not medical) and psychological testing (subject to abuse).
- Industry reps expressed concern that outpatient behavioral health treatment is not analogous to outpatient medical treatment because the potential for misuse is much higher.
- Members of the expert panel recognized that network panel adequacy is a non quantitative treatment limitation, therefore fees so low for behavioral health services that a lack of providers willing to accept them creates an inadequate panel could be a parity violation.
- In the scope of service analysis, RAND found that behavioral health treatment makes up only $12 of the $268 per member per month health care costs. Of that $12, more than 60% is spent on prescription drugs, and only 20% is spent on intermediate services for those plans that currently provide them.
It is likely that this study will impact the specificity of the not yet released, final regulations for the Mental Health Parity and Addiction Equity Act. For more information on this report or to stay up to date on the regulatory process- Sign Up for Alerts