Please take a moment to submit a comment on the proposed rule to make the Mental Health Parity and Addiction Equity Act more enforceable. You may use the template below or write your own. Comments are due on October 2, 2023.
To read the document visit https://www.regulations.gov/document/EBSA-2023-0010-0001.
To submit a comment visit https://www.regulations.gov/commenton/EBSA-2023-0010-0001.
Template:
Subject: Re: 0938-AU93 1210-AC11 1545-BQ29 Requirements Related to the Mental Health Parity and Addiction Equity Act
Dear Secretary Becerra, Assistant Secretary Gomez, and Deputy Commissioner O’Donnell;
Thank you for the opportunity to comment on the Requirements Related to the Mental Health Parity and Addiction Equity Act (MHPAEA) proposed rule. I write as a licensed clinical social worker who has noticed increased difficulty for patients to find coverage for mental health and substance use (MH/SUD) treatment.
It is quite unfair that mental health and substance use treatment is still not covered at parity with medical/surgical care after the initial rules for the 2008 MHPAEA were delayed until 2014 and are still not covered at parity almost 10 years later.
Please finalize the following specific proposals WITHOUT EXCEPTION:
• Requiring health plans to prove their MH/SUD parity compliance by showing the effect the limits they place on benefits have on a person’s access to treatment; • Evaluating the health plan’s provider network, including how long the wait times are; how often consumers must seek out-of-network providers; how much a plan pays providers; how often prior authorization is required for services a practitioner prescribes; and how often prior authorization requests are denied; and • Imposing strong consequences when a plan is found to be out of compliance with the parity requirements, including barring them from imposing the plan requirement.
• Requiring health plans to prove their MH/SUD parity compliance by showing the effect the limits they place on benefits have on a person’s access to treatment;
• Evaluating the health plan’s provider network, including how long the wait times are; how often consumers must seek out-of-network providers; how much a plan pays providers; how often prior authorization is required for services a practitioner prescribes; and how often prior authorization requests are denied; and
• Imposing strong consequences when a plan is found to be out of compliance with the parity requirements, including barring them from imposing the plan requirement.
We urge the Departments to consider penalties when plans ignore these consequences.
Please make these changes to eliminate barriers to care and ensure that everyone has the same access to mental health and substance use benefits as they do physical health benefits.
Thank you again for the opportunity to comment.
As always, let me know when you have submitted your comments.
Laura Groshong, LICSW, Director of Policy and Practice
lwgroshong@clinicalsocialworkassociation.org
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