MPS Advocacy on Parity Accreditation

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.

Patients need your help to enforce mental health parity! 

With all the recent discussion of the future of the Affordable Care Act (ACA), members have asked about the impact of the ACA’s destiny on the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA). MHPAEA is a separate statute that applies to large group employer plans (+50 people), Medicaid managed care arrangements and nonfederal government plans that do not opt out. The ACA expanded MHPAEA to Medicaid expansion plans, Exchange Plans and to the individual and small group markets. Right now, MHPAEA impacts almost all insurance products on the market, and your patients need your help in dealing with possible parity issues and ensuring access to care. What can you do? Please click here for step by step directions and helpful websites.

  • Help patients understand their rights under the federal mental health parity law by making this poster available in your office.
  • SAMHSA has a tri-fold brochure that can be distributed in waiting areas to alert patients to their rights and protections under the parity law.

Report Parity Violations

The Parity Track website has a place to register complaints about health plans’ denial or restriction of care.  Parity Track partners include the Kennedy Forum and the Scattergood Foundation; its coalition also includes Mental Health America, NAMI and others.

For assistance with parity complaints:

Colleen Coyle, APA General Counsel, can help assess possible parity violations.

Sam Muszynski, APA Director of Healthcare Systems and Financing, is another resource (call 202-609-7078).

You can also FAX information below to Maureen Bailey at APA – 703-907-1089

  1. Name of patient’s insurance company
  2. Source of the insurance for the patient (Medicare, exchange plan, employer plan and if so, name of employer if you know it)
  3. Name of the pharmacy benefit company
  4. Drug requiring pre cert
  5. Time you spent trying to get the prior authorization
  6. Any impact on the patient while waiting.

Or, contact the Maryland Parity Project at 443-901-1550.