By Catherine Ford
Commonwealth Strategy Group
Newly Proposed Federal Parity Rules
Last month the departments of Labor, Health and Human Services (HHS), and Treasury announced a series of rule proposals to strengthen the protections of the Mental Health Parity and Addiction Equity Act to better ensure that individuals seeking coverage for mental health and substance use disorder care can access treatment services as easily as those seeking coverage for medical treatments.
Specifically, the proposed regulations would:
- Make clear that MHPAEA requires that individuals can access their mental health and substance use disorder benefits in parity with medical/surgical benefits.
- Provide specific examples that make clear that plans and issuers cannot use more restrictive prior authorization and other medical management techniques for mental health and substance use disorder benefits; standards related to network composition for mental health and substance use disorder benefits; and factors to determine out-of-network reimbursement rates for mental health and substance use disorder providers.
- Require plans and issuers to collect and evaluate outcomes data and take action to address material differences in access to mental health and substance use disorder benefits as compared to medical/surgical benefits, with a specific focus on ensuring that there are not any material differences in access because of the application of their network composition standards.
- Codify the requirement that plans and issuers conduct meaningful comparative analyses to measure the impact of NQTLs. This includes evaluating standards related to network composition, out-of-network reimbursement rates, and prior authorization NQTLs.
Behavioral Health Provider Coalition, Right Help Right Now, and Medical Society of Virginia
The PSV government relations team has been busy this year! This spring, the Psychiatric Society joined forces with other behavioral health provider groups to discuss mental health cost and access solutions. We have discussed parity, collaborative care, and network adequacy. While our legislative solutions are not final yet, building a coalition of providers lends a strong voice to our unique needs as mental health providers.
As you know, PSV has been actively engaged with the Youngkin Administration’s mental health transformation efforts, Right Help Right Now. We have worked with the Department of Behavioral Health and Developmental Services, Department of Health professions, and the Department of Medical Assistance Services to improve mental health care in Virginia. Specifically, we have touted the Collaborative Care Model as a way to access Psychiatric care through primary care settings.
In June, PSV’s own Dr. Sherin Moideen presented a resolution at the Medical Society of Virginia’s Advocacy Summit to solicit the association’s support for Collaborative Care efforts and funding in the upcoming legislative session.
Delegate Visits EVMS Psychiatric Residents
Delegate Jackie Glass (HD 89, Norfolk) joined Psychiatric residents at Eastern Virginia Medical School on July 26 to discuss state level policy advocacy and why their expert voices matter to policymakers.
PSYCHMD PAC
None of these accomplishments would be possible without PSV’s strong government relations program, which includes professional lobbying, grasstops and grassroots advocacy, and our political action committee (PAC). PSYCHMD PAC is a critical component to our effectiveness; it allows us to support legislators who support our profession, practice, and patients. PSYCHMD PAC allows us to introduce ourselves to and build relationships with new, returning, and key legislators.
This is a critical election year in Virginia. All 100 seats in the House of Delegates and all 40 seats in the State Senate are up for grabs. No matter the results, the entire legislative body of Virginia will have more newcomers than we have seen in decades, up to 55 new legislators could be sworn in this January.
2023 is a major election year in Virginia, help us introduce PSV to our new legislators and give to the PSYCHMD PAC!
Or mail a check payable to PsychMD PAC to 118 N. 8th Street, Richmond, VA 23219.
