Mental Health Parity Accreditation

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

The ClearHeath Quality Institute (CHQI) Mental Health Substance Use Disorder (MH/SUD) Parity Accreditation Program establishes the nation’s first accreditation standards outlining a logical sequence of steps for health insurers, health benefits administrators and others to assess their compliance with the Mental Health Parity and Addiction Equity Act (the Federal Parity Law).

The MH/SUD Parity Accreditation Program offers an effective pathway to help health insurers and other organizations better understand how to prepare for and implement strategies to comply with the federal and state parity requirements. The Parity Accreditation Standards incorporate parity regulations and guidance, as well as the experience and insight of national thought leaders, including the Parity Standards Committee members. The Program also provides an opportunity for applicants to re-evaluate and update their utilization management and benefits administration programs.

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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 (the Federal Parity Law) and its implementing regulations require parity for financial requirements, quantitative treatment limitations, and non-quantitative treatment limitations. 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.

What is the CHQI MH/SUD Parity Accreditation Program?

The CHQI MH/SUD Parity Accreditation Program establishes 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 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  accreditation program provides 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 MH/SUD Parity Accreditation Program necessary?

Until now, no existing accreditation program focused on the Federal Parity Law or delved deeply into its required testing.

Compliance with the Federal Parity Law is challenging due to the complexity of the law and its fragmented enforcement regime. For example, about one-fourth of Americans have health insurance regulated primarily through state insurance agencies through commercial insurance offerings; a third have employer self-funded health plans regulated by the U.S. Department of Labor (USDOL); one-fifth have Medicaid, which is regulated jointly by the U.S. Centers for Medicare and Medicaid Services (CMS) and the states; and about 14% have Medicare which is regulated by CMS.

Regulators, health insurers, providers, and consumer advocates are attempting to assess compliance with the Federal Parity Law through various approaches. The CHQI Mental Health Parity Accreditation Program creates a uniform set of national accreditation standards for the Federal Parity Law testing processes.

Who seeks CHQI MH/SUD Parity Accreditation and for what purpose?

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

How were CHQI’s MH/SUD Parity Accreditation Program Standards developed?

The MH/SUD Parity Accreditation Standards were 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,  intensively reviewed every aspect of the Parity Accreditation Standards as well as program operational issues during dozens of committee and subcommittee meetings.

In addition, CHQI hosted a 60-day public comment period during the summer of 2018, and received dozens of letters providing feedback. Ultimately, CHQI’s Advisory Board has the authority to approve the Parity Accreditation Standards. The Board is scheduled to review the final draft Parity Accreditation Standards towards the end of 2018. We are optimistic that we will be officially launching the program by the end of the year.

Was there a public comment process prior to finalizing the CHQI MH/SUD Parity Accreditation Program Standards?

Yes, before finalizing the CHQI MH/SUD Parity Accreditation Program Standards, CHQI held a public comment period to receive feedback from third parties, including health insurers, employers, consumers, providers, and federal and state regulators. The CHQI Parity Standards Committee and the CHQI Advisory Board reviewed public comments and feedback before finalizing the MH/SUD Parity Accreditation Program Standards and launching the CHQI MH/SUD Parity Accreditation Program.

Who makes the final decision on a CHQI MH/SUD Parity Accreditation Program application?

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

What is the length of accreditation under the CHQI MH/SUD Parity Accreditation Program?

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

Does achieving CHQI MH/SUD Parity Accreditation Program deem an entity compliant with the Federal Parity Law?

No, only federal and state regulatory agencies and courts possess authority to determine whether a covered entity complies with the Federal Parity Law. Regulators may look to the CHQI MH/SUD 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 MH/SUD Parity Accreditation Standards to conclude that an organization has implemented processes that enable it to perform the rigorous comparative analyses needed to determine the Federal Parity Law compliance.

Additionally, regulators may require organizations to provide the documentation required by the MH/SUD 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.

Will achieving CHQI MH/SUD Parity Accreditation help insurers and health benefit plans achieve better treatment outcomes?

Although it is not currently possible to state that achieving CHQI MH/SUD 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 MH/SUD Parity Accreditation Program facilitates 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 MH/SUD 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
  • 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