The Clear Health Quality Institute (CHQI) published a Draft Mental Health Parity Accreditation Program Standards and Guide with a request for feedback. In coordination with the APA and other parity advocates, the MPS expressed concern that adoption of these standards would ultimately undermine patient care and the progress on mental health parity that has been achieved to date. Several major problems were noted.
- First is the limitations of an accreditation program to improve enforcement of a civil rights law and the risk that it might confer a “seal of approval” that is misleading since the question of whether the non-discrimination tests are met in a specific situation requires legal judgment.
- Second, the draft standards are incomplete since they do not include essential metrics, such as full data on denial rates and out-of-network utilization, or full disclosure regarding the source information and/or evidentiary standards used to define the factors upon which NQTLs are based.
- Third is the lack of robust infrastructure and personnel with qualified parity experience to review applicants.
- Finally, it is unclear to whom and to what the status of any accreditation would apply. The vast array of health plans in the marketplace, e.g. commercial arrangements, self-insured plans, etc., many with subcontractor functions built in makes it very complicated to clarify who the applicant is and the scope of what their accreditation status means. Every component is integral to a parity compliance evaluation.
The MPS also noted that the Federal Self Compliance Tool is available to any health plan that wishes to be transparent and demonstrate compliance. It can simply follow and document the process outlined in this newly issued Compliance Tool and publicly post the results. Click here for the MPS comment letter.