Mental Health Parity Accreditation

Welcome to the ClearHealth Quality Institute (CHQI) Mental Health Parity Accreditation Program

The CHQI Mental Health Parity Accreditation Program, which has been in development since March 2017, will establish the nation’s first accreditation standards outlining a logical sequence of steps for health insurers and health benefits administrators to assess their MHPAEA compliance processes.

The Mental Health Parity Accreditation Standards will reflect MHPAEA regulations and guidance, as well as the experience and insight of CHQI staff (who possess extensive parity enforcement experience) and Parity Standards Committee members. The new accreditation program will provide a navigational road map to help health insurers and other organizations better understand how to prepare for and implement strategies to comply with MHPAEA and related state laws.

What is Mental Health Parity and why is it important?

Historically, health insurance benefits for mental health and substance use disorder treatment have been less generous than for treatment for physical health conditions. Mental health parity laws are designed to remedy these inequities, requiring health insurers to cover mental health and substance use disorder services at benefit levels matching corresponding medical and surgical benefits.The Mental Health Parity and Addiction Equity Act (MHPAEA) and its implementing regulations require parity for financial requirements (e.g., copayments, coinsurance, etc.), quantitative treatment limitations (e.g., limits on hospitalization days and outpatient visits, etc.) and non-quantitative treatment limitations (e.g., prior authorization requirements, provider networks, etc.). In addition, states have passed mental health parity laws, which must be consistent with MHPAEA, along with other legislative initiatives that promote parity such as mandated benefits and network adequacy requirements.Achieving mental health parity – and the parity laws’ goal of improving access to mental health and substance use disorder treatment – has never been more critical, because our country is facing opioid and suicide epidemics. According to the Centers for Disease Control and Prevention, in 2016, there were more than 64,000 drug overdose deaths. The opioid epidemic cost the U.S. economy approximately $500 billion in 2015 alone, according to the White House Council of Economic Advisers.

What is the CHQI Mental Health Parity Accreditation Program?

The CHQI Mental Health Parity Accreditation Program, which has been in development since March 2017, will establish the nation’s first accreditation standards outlining a logical sequence of steps for health insurers and health benefits administrators to assess their MHPAEA compliance processes. The Mental Health Parity Accreditation Standards will reflect MHPAEA regulations and guidance, as well as the experience and insight of CHQI staff (who possess extensive parity enforcement experience) and Parity Standards Committee members. The new accreditation program will provide a navigational road map to help health insurers and other organizations better understand how to prepare for and implement strategies to comply with MHPAEA and related state laws.

Why is CHQI’s Mental Health Parity Accreditation Program necessary?

No existing accreditation program focuses on MHPAEA or delves deeply into its required testing. Compliance with MHPAEA is challenging due to the complexity of the law and its fragmented enforcement regime. One-fourth of Americans have health insurance regulated jointly by state agencies and U.S. Department of Labor (USDOL); a third have health insurance regulated only by USDOL; and one-fifth have Medicaid, which is regulated jointly by the U.S. Centers for Medicare and Medicaid Services (CMS) and the states. CMS also exercises jurisdiction over state and local governmental employee health plans, and the U.S. Department of Health and Human Services has jurisdiction over health insurance issuers.
Regulators, health insurers, providers, and consumer advocates are attempting to assess compliance with MHPAEA through various approaches. The CHQI Mental Health Parity Accreditation Program will create a uniform set of national accreditation standards for MHPAEA testing processes.

Who will seek CHQI Mental Health Parity Accreditation and for what purpose?

The entities that may apply for CHQI Mental Health Parity Accreditation include health insurers, employee health benefit plans, and health benefits administrators. Accreditation will help these entities prepare for regulatory audits, supplement risk management programs, and demonstrate that they have implemented robust internal MHPAEA compliance processes. In addition, the Parity Accreditation Standards will facilitate implementation of appropriate MHPAEA compliance protocols and procedures, staff oversight, coordination with third-party vendors and documentation.

Organizations that achieve CHQI Mental Health Parity Accreditation will be able to demonstrate to internal and external stakeholders and to the marketplace that they have taken critical steps towards complying with MHPAEA. Receiving Mental Health Parity Accreditation from CHQI, however, will not represent a conclusion that an organization complies with MHPAEA. Rather, CHQI’s accreditation seal will demonstrate an independent third-party’s informed assessment that a health insurer or health plan has conducted requisite MHPAEA testing. The Mental Health Parity Accreditation Program also will have direct relevance to processes for compliance with state mental health parity laws, which may explicitly reference MHPAEA or contain similar requirements.

How are CHQI’s Mental Health Parity Accreditation Standards being developed?

CHQI recognizes that for the Mental Health Parity Accreditation Standards to be credible, they must be vetted by a Parity Standards Committee that encompasses a broad range of perspectives, including health insurers, health benefits administrators, provider organizations, consumer advocacy organizations, and former regulators. The CHQI Parity Standards Committee, which reflects all these viewpoints, has intensively reviewed every aspect of the Mental Health Parity Accreditation Standards as well as program operational issues during dozens of committee and subcommittee meetings.

The Parity Standards Committee is a standing committee of the CHQI Advisory Board. The Mental Health Parity Accreditation Standards will be reviewed and approved by both the Parity Standards Committee and the CHQI Advisory Board.

Will there be a public comment process prior to finalizing the CHQI Mental Health Parity Accreditation Standards?

Yes, before finalizing the Mental Health Parity Accreditation Standards, CHQI will hold a public comment period to receive feedback from third parties, including health insurers, employers, consumers, providers, and federal and state regulators. In addition, CHQI will host a “beta test cycle” to vet the Mental Health Parity Accreditation Standards with several applicants. The CHQI Parity Standards Committee and the CHQI Advisory Board will review public comments and feedback received from the beta testing before finalizing the Mental Health Parity Accreditation Standards and launching the Mental Health Parity Accreditation Program.

Who will make the final decision on a CHQI Mental Health Parity Accreditation application?

The CHQI Accreditation Committee will make all decisions on accreditation applications, based on its independent assessment of blinded summaries of applicants’ accreditation submissions, which will be compiled by trained CHQI reviewers with health care expertise. The CHQI Accreditation Committee will be comprised of a broad range of stakeholders with deep experience in the health care field, including clinicians, consumer advocates, health technology experts, health system leaders, and health insurance executives. CHQI Accreditation Committee members will be vetted and appointed by the CHQI Advisory Board. CHQI imposes a strict conflicts of interest policy on all committee members.

What will be the length of accreditation under the CHQI Mental Health Parity Accreditation Program?

CHQI will grant accreditation for a two-year period to health insurers and health plans that satisfy all Mental Health Parity Accreditation Standards. CHQI anticipates periodically revising the Mental Health Parity Accreditation Standards to reflect regulatory developments and best practices. In the interim, CHQI will incorporate any MHPAEA guidance issued by federal regulators into the Mental Health Parity Accreditation Program.

Does achieving CHQI Mental Health Parity Accreditation deem an entity compliant with MHPAEA?

No, only federal and state regulatory agencies possess authority to determine whether a covered entity complies with MHPAEA. Regulators may look to the CHQI Mental Health Parity Accreditation Standards for a template to structure their compliance audits, policy review processes, and market conduct examinations. Regulators also may rely upon the CHQI Mental Health Parity Accreditation Standards to conclude that an organization has implemented processes that enable it to perform the rigorous comparative analyses needed to determine MHPAEA compliance. Additionally, regulators may require organizations to provide the documentation required by the Mental Health Parity Accreditation Standards as part of their compliance assessment. Organizations that have achieved Mental Health Parity Accreditation should be well prepared to respond to such requests. Regulators may require additional information and will reach independent conclusions regarding MHPAEA compliance.

Will achieving CHQI Mental Health Parity Accreditation help insurers and health benefit plans achieve better treatment outcomes?

Although it is not currently possible to state that achieving CHQI Mental Health Parity Accreditation will promote better treatment outcomes, studies suggest that MHPAEA has resulted in improved benefits for and access to mental health and substance use disorder treatment. Additionally, population health experts believe that clinical and financial outcomes may improve when patients are treated holistically for all their key co-morbidities, including mental health and substance use disorder conditions. To the extent that the CHQI Mental Health Parity Accreditation Program will facilitate more robust MHPAEA testing by health insurers and health plans, it may improve access to quality mental health and substance use disorder treatment.

How can I learn more about CHQI and the Mental Health Parity Accreditation Program, or become involved with one of the CHQI committees?

CHQI offers a number of accreditation programs and educational workshops and webinars, and welcomes public involvement with our committees. If you would like to learn more about CHQI or the CHQI committee nomination process, please send an email to info@chqi.com or call (410) 756-1300.

CHQI Mental Health Parity Standards Committee

Co-Chairs:

  • Connie Galietti, JD, Director, Legal & Professional Affairs, Practice Directorate, American Psychological Association, Provider
  • Bradley Lerner, JD, Associate General Counsel & Director, Parity Compliance, Beacon Health Options, Payer

 

Members:

  • Paul Berman, Ph.D., Director, Towson Addictions Center, Provider
  • Theresa Canavera-Schad, JD, Compliance and Specialty Regulatory Compliance, Humana, Payer
  • Mirean Coleman, MSW, LICSW, CT, Clinical Manager, National Association of Social Workers, Provider
  • Nathaniel Counts, JD, Senior Director of Policy, Mental Health America, Advocate
  • Rebecca Farley David, MPH, Vice-President, Policy & Advocacy, National Council for Behavioral Health, Advocate
  • Adam Easterday, JD, Deputy General Counsel, Optum – Consumer Solutions Group, Payer
  • Paul Galvin, JD, Legal Counsel, Anthem, Payer
  • Pamela Greenberg, MPP, President & CEO, Association for Behavioral Health and Wellness, Payer
  • Scott D. Hagaman, MD, Provider
  • Randall Madry, Former CEO, Carolina Sumit Healthcare, Inc., Payer
  • Machael C. Markowicz, JD,Counsel, Behavioral Health, Aetna, Payer
  • Pamela Mobberley, JD, Counsel for Behavioral Health Operation, Cigna Legal, Payer
  • Tara Ragone, JD, Research Fellow & Lecturer in Law, Seton Hall Law, Advocate
  • Michael J. Rice, PhD, APRN, FAAN, Endowed Chair & Professor of Psychiatric Nursing, University of Colorado College of Nursing, Provider
  • Andrew Sperling, JD, Director of Legislative Advocacy, National Alliance on Mental Illness, Advocate

CHQI Mental Health Parity Accreditation Standards Public Comment Period

Historically, health insurance benefits for mental health and substance use disorder treatment have been less generous than for treatment for physical health conditions. Mental health parity laws are designed to remedy these inequities, requiring health insurers to cover mental health and substance use disorder services at benefit levels matching corresponding medical and surgical benefits.

The purpose of CHQI’s Mental Health Parity Accreditation Program is to create a uniform set of national accreditation standards for health plans, health insurers, and health benefits administrators to demonstrate a framework for assessing compliance with the Mental Health Parity and Addiction Equity Act (“MHPAEA”), and to facilitate implementation of appropriate MHPAEA compliance protocols and procedures, staff oversight, and coordination with third-party vendors, to enable these entities to prepare for regulatory audits and market conduct examinations. CHQI anticipates that improved compliance with mental health parity laws will result in greater access to effective mental health and substance use disorder treatment.

The public comment period begins on June 21, 2018 and concludes at 5:00 p.m. EST on August 21, 2018.  The CHQI Parity Standards Committee will use feedback submitted by the deadline to prepare the standards for approval and adoption by the CHQI Advisory Board.

Obtaining a Copy of the Draft Mental Health Parity Accreditation Standards and Submitting Comments

To request a copy of CHQI’s Draft Mental Health Parity Accreditation Standards for review and to provide feedback, please submit the requested information in the form below. You will immediately receive a copy of the Draft Mental Health Parity Accreditation Standards. Please provide comments to CHQI through a Word document sent to MHPaccred@chqi.com.


Draft Mental Health Parity Accreditation Standards

To receive a copy of the draft CHQI Mental Health Parity Accreditation Standards, please complete the below form.
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