Mental Health Parity Accreditation

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

The ClearHealth 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. 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 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 or the Federal Parity Law) and its implementing regulations require parity for financial requirements, quantitative treatment limitations and non-quantitative treatment limitations. In addition, a number of 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, as our nation continues to mental health and substance use disorder epidemics.

Who is eligible for the CHQI Mental Health/Substance Use Disorder (MH/SUD) Parity Accreditation Program?

The CHQI MH/SUD Parity Accreditation Program is available for any health plan, TPA, Medicaid Care Organization or Self-Funded Plan that is required to be parity complaint under Federal Parity laws.

The program helps these entities prepare for regulatory audits, supplement risk management programs, and demonstrate that they have implemented robust Federal Parity Law compliance processes. In addition, the CHQI MH/SUD Parity Accreditation Standards facilitate implementation of appropriate Federal Parity Law compliance protocols and procedures, staff oversight, and coordination with third-party vendors and documentation.

What are the different components of the CHQI Mental Health/Substance Use Disorder (MH/SUD) Parity Accreditation Program?

The CHQI MH/SUD Parity Accreditation Program is comprised of three components:

• The CHQI MH/SUD Parity Compliance Guide is a comprehensive research document that summarizes key regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA) and provides practical guidance on how to ensure compliance.

ParityManager™ is CHQI’s intuitive, online system that organizes and evaluates all supporting operational documents necessary to demonstrate parity compliance. The streamlined process:

o Identifies and classifies covered benefits
o Creates a framework for quantitative testing of financial requirements and quantitative treatment limits (QTLs)
o Implements an innovative approach to collecting and organizing data necessary to perform comparability and stringency testing for nonquantitative treatment limits (NQTLs)
o Automatically identifies a wide range of per-se parity violations and areas where the user lacks information necessary to complete the parity compliance analysis
o Generates important feedback loops and reports to ensure parity compliance optimization

• The CHQI MH/SUD Parity Accreditation Program establishes the nation’s first accreditation standards for health insurers and health benefits administrators to assess their MHPAEA compliance processes. The CHQI MH/SUD Parity Accreditation Standards reflect MHPAEA regulations and guidance, as well as the experience and insight of CHQI staff, CHQI Consultants and CHQI 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. The accreditation program utilizes ParityManager™ and its reporting function to gather information that is used when making an accreditation decision.

What are the benefits of the CHQI MH/SUD Parity Accreditation Program?

The CHQI MH/SUD Parity Accreditation Program:

• Is the first private, independent accreditation program focused on parity compliance for health plans and third-party administrators, and other types of insurers
• Offers a navigational roadmap for assessing compliance with the Federal Parity Law and applicable state laws
• Helps health insurers and plans demonstrate how behavioral health services are covered at the same levels as corresponding medical and surgical benefits
• Includes key resources including accreditation standards, ParityManager™, an intuitive, online system that organizes and evaluates operational documents necessary to demonstrate parity compliance, and a regulatory compliance guide developed over a two-year period and vetted by a broad range of stakeholders
• Uses a streamlined online process and framework that helps applicants build a parity compliance program, including “NQTL” comparability analysis, no matter what their starting point is
• Leverages consulting solutions to help applicants prepare for accreditation, regulatory audits and market conduct examinations

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 MH/SUD Parity Accreditation Program creates a single set of national accreditation standards for the Federal Parity Law testing process.

If my organization earns CHQI accreditation, how does CHQI assist my organization in announcing and promoting my accreditation?

CHQI provides marketing and communications support and guidance to accredited organizations, including a detailed listing in CHQI’s online Accreditation Directory, as well as through the CHQI Marketing Guide for MH/SUD Accreditation, which provides specific recommendations, strategies and tactics for promoting accreditation.

How do I apply for CHQI MH/SUD Parity Accreditation?

The first step in the application process is to contact CHQI in order to be evaluated for eligibility. CHQI can be contacted at info@chqi.com or 410-756-1300.

How do I submit my application and documentation to CHQI?

After being deemed eligible and executing the accreditation agreement, applicants will upload all materials and supporting documentation through CHQI’s HIPAA-compliant, cloud-based submission portal.

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 intensively reviewed every aspect of the MH/SUD Parity Accreditation Standards as well as program operational matters during an 18-month long process of committee and subcommittee meetings.

CHQI’s MH/SUD Parity Accreditation Standards also incorporate input received during a 60-day public comment period from numerous individuals and organizations, including medical societies, regulators and consumers. Using this feedback, the standards were then revised by the Parity Standards Committee and approved by CHQI’s Advisory Board.

What are the fees associated with the accreditation program?

Accreditation fees are tailored to each organization based on the unique characteristics of each program and the scope of review by CHQI. CHQI is committed to keeping accreditation fees reasonable and each applicant will receive a written quote as part of the review process when determining program eligibility. The CHQI MH/SUD Parity Accreditation Program includes a license to ParityManager™, an intuitive, online system that organizes and evaluates operational documents necessary to demonstrate parity compliance, throughout the term of the accreditation period.

How long does the accreditation process take?

There are several factors that can affect the length of time it takes for an organization to complete the accreditation process. The program is designed to be completed in as little as two (2) to four (4) months for organizations that are ready to submit all required evidence and satisfy the standards.

In cases where an organizations may discover gaps in policies and procedures while working on the CHQI application, the time required for internal vetting and approval may increase the length of time an organization needs to complete the process. Timeline requirements are clearly identified in the application materials, so there are no surprises throughout the accreditation application and review process.

What is the length of the accreditation cycle?

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 MH/SUD Parity Accreditation Standards to reflect regulatory developments and best practices. In the interim, CHQI will incorporate any new Federal Parity Law guidance issued by federal regulators into the MH/SUD Parity Accreditation Program.

How is the review conducted?

Numerous individuals will be involved in reviewing each application. Each applicant is assigned an Account Manager to coordinate the overall process to ensure completeness prior to passing the application to the review team. The review team consists of an Administrative Reviewer, Technology Reviewer, Parity Specialist and Legal Reviewer, who will each substantively review the application materials and make a recommendation for accreditation to the CHQI Accreditation Committee.

After the application and supporting documentation have been submitted, the Account Manager will work with the applicant to finalize any outstanding issues prior to submission to CHQI’s Accreditation Committee.

What happens if areas of non-compliance with any of the accreditation standards are found during the review process?

As part of the accreditation review process, organizations will be notified of any deficiencies in the application and supporting documentation following the preliminary review of the application. Applicants will be afforded a reasonable period to address any deficiencies before the on-site visit will be scheduled.

Who makes the final decision on an accreditation application?

The CHQI Accreditation Committee makes all decisions on accreditation applications. The CHQI Accreditation Committee is comprised of a broad group of stakeholders, including providers, industry representatives, consumers, employers, legal experts, and others. Accreditation Committee members are vetted and appointed by CHQI’s Advisory Board. All accreditation applications reviewed by the Accreditation Committee remain confidential to ensure the integrity and objectivity of the accreditation review process.

What options are available to an applicant who receives an adverse decision such as denial or revocation of accreditation by the CHQI Accreditation Committee?

If an organization receives an adverse accreditation decision, CHQI staff will provide details about the appeals process at the time the applicant is informed about the decision. CHQI affords applicants receiving an adverse decision two levels of appeal, first to the CHQI Accreditation Committee and then to the CHQI Advisory Board. CHQI does not make public adverse actions by the CHQI Accreditation Committee or the results of appeals.

Is my accreditation status available to the public?

Yes. Once accredited, each organization will be listed on CHQI’s Online Directory of Accredited Organizations. All accredited organizations are encouraged to issue a press release announcing the accreditation determination as long as CHQI’s marketing guidelines are followed. In some cases, CHQI also might issue a press release referencing one or more accredited organizations. In addition, accredited organizations must display the official seal of the CHQI Accreditation Program on their website.

Is the data and information collected from my organization during the accreditation process kept confidential?

Yes, all accreditation application information is kept confidential, unless disclosure is required by law.

Does an accredited organization have any ongoing reporting requirements to CHQI?

Accredited organizations are required to notify CHQI about changes, including but not limited to things such as changes in ownership. All requirements are outlined in CHQI’s MH/SUD Parity Accreditation Agreement.

Does utilizing the CHQI Online Parity and Audit Tool and/or achieving CHQI MH/SUD Parity Accreditation 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 as a template to structure their compliance audits, policy review processes, and market conduct examinations. Regulators may also 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 CHQI MD/SUD Parity Accreditation should be well prepared to respond to such requests.

How can I learn more about CHQI and the MH/SUD Parity Accreditation Program?

CHQI offers a number of accreditation programs and educational workshops and webinars. If you would like to learn more about CHQI or receive more information about the MH/SUD Parity Accreditation Program, please email info@chqi.com or call (410) 756-1300.