Promoting MH/SUD Health Insurance Parity Through Accreditation

For the past 20 years, federal and state governments have enacted laws with the goal of eliminating disparities between the scope of health insurance coverage for mental health and substance use disorder (MH/SUD) services and medical/surgical benefits. The best known law is the federal Mental Health Parity and Addictions Equity Act of 2008 (MHPAEA). Over the years, MHPAEA’s regulatory and subregulatory guidance has evolved to provide greater specificity and direction to help health insurers, managed care organizations, employers, health benefit administrators and other covered entities become parity compliant.

However, promoting health equity is easier said than done. Although the concept of parity is straightforward in the abstract, it has proven to be extremely challenging for multiple state and federal regulators to develop and consistently apply a clear methodology for comparing all functions of modern managed care organizations.

These challenges make it difficult to effectively review whether or not health insurers and other covered entities are implementing benefits in compliance with parity. Barriers include:

  • The fragmentation of the health insurance market place –many plans subcontract out the management of MH/SUD services to specialized vendors, and some important plan types are subject to federal and state parity laws while other plans (such as Medicare Advantage) are not covered at all;
  • the extensive resources needed for regulators to complete a meaningful review;
  • the lack of a standardized market conduct exam across markets to facilitate consistent reviews;
  • the sheer number of different insurance policies with different limit types that are offered today;
  • the fact that comparing management functions that apply to MH/SUD services with those that apply to medical/surgical services is not always an apples to apples assessment;
  • the reality that evidence-based pathways are often complex, or sometimes non-existent, for populations with co-morbidities, among other barriers.

The good news is regulators have been successful in creating standards and auditing how financial criteria (such as copayments and deductibles) are used to ensure parity. Unfortunately, it has been much more difficult to implement a meaningful and standardized approach to audit the non-financial criteria. Opinions and practices continue to vary among regulators regarding the best approach to assess how non-quantitative treatment limitations (i.e. non-financial criteria) are applied, which can greatly impact the scope and duration of insurance benefits.

This is where accreditation can help. The CHQI MH/SUD Parity Accreditation Program represents the nation’s first accreditation standards for covered entities to provide a robust independent assessment of their ability to comply with the requirements of MHPAEA, helping to ensure that MH/SUD health insurance benefits are offered in an equitable fashion when compared to medical/surgical benefits.

After working with a diverse group of stakeholders for two years, CHQI created is own unique roadmap to promote standardization and raise the bar of parity compliance across the industry. The CHQI MH/SUD Parity Accreditation Program is comprised of three components:

  • The MH/SUD Parity Program Standards and Guide provides a roadmap for organizations to develop, implement and maintain a parity compliance program pursuant to MHPAEA requirements. This guide is the core document that applicants will use when applying for accreditation.
  • ParityManager™ is a comprehensive digital resource designed to help health plans and other organizations build, implement and manage an effective parity compliance program. The intuitive, online system organizes all of the organization’s supporting operational documents necessary to maintain compliance and apply for accreditation. The secure platform also can be licensed separately by health plans, third party administrators and others to help build and maintain their respective parity compliance programs even without applying for accreditation.
  • The CHQI MH/SUD Parity Compliance Guide is a comprehensive compliance tool that summarizes key regulations under MHPAEA. The Guide aggregates the key federal regulatory and sub-regulatory guidance into topic areas and provides practical insights and guidance on how to ensure compliance.

Although healthcare accreditation solutions are not a panacea, many examples exist where national standards have been developed by accreditation agencies to help fill regulatory gaps, promote standardization, and make the oversight process more efficient.

If you would like to learn more about how CHQI’s new MH/SUD Parity Accreditation Program can make a difference in your organization, contact info@chqi.com.

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