ABHW Responds to The Kennedy Forum and American Medical Association Mental Health Parity Index

Washington, D.C. – April 14, 2026  — The Association for Behavioral Health and Wellness (ABHW) appreciates the work done by The Kennedy Forum and its collaborators, Third Horizon, the American Medical Association (AMA), the American Psychological Foundation, and Ballmer Group, to advance critical measurement in behavioral health care in pursuit of parity with medical and surgical care. ABHW looks forward to collaborating with these and other stakeholders to make this work even more comprehensive.

The group has released a “Mental Health Parity Index,” which highlights tremendous progress over the past two decades and the extensive contributions of health plans in offering mental health benefits to hundreds of millions of Americans. The data tells a revealing story about the challenges of network adequacy the American health care system continues to face, in both medical/surgical and behavioral health care.

ABHW believes the Index has the potential to paint an accurate picture of mental health care in the United States, with some notable additions. Behavioral health is increasingly delivered through integrated primary care models, which play a critical role in expanding access, reducing stigma, and improving outcomes by supporting early identification and intervention. Primary care often serves as the front door to the health system, offering a trusted, accessible setting where patients can receive whole-person care that addresses both physical and behavioral health needs. These primary care models improve coordination and continuity.  

Additionally, the Index does not include data on tele-behavioral health utilization, even though growth in this area has been exponential over the past six years. Telehealth has expanded access, especially in underserved areas. 

By capturing behavioral health services that are delivered through telehealth and primary care, the Index would present a more comprehensive and accurate picture of access and treatment. 

A second key area for improving the Index is increasing alignment with the federal parity framework. The Mental Health Parity and Addiction Equity Act (MHPAEA) focuses on comparable treatment limitations and financial requirements. The Index emphasizes reimbursement, a different policy dimension than the MHPAEA framework. Clarifying this distinction supports an accurate understanding of parity.

Even though MHPAEA is about much more than reimbursement, ABHW believes the reimbursement methodology in the Index needs retooling. For example, the Index compares aggregate reimbursement across sectors. Like-to-like comparisons across providers would improve accuracy—currently, non-physician MH/SUD clinicians (e.g., licensed therapists) are compared to non-physician M/S providers (e.g., speech–language pathologists). It’s worth noting that differences may reflect structural variation rather than disparities.

Yet another area for improvement is in consideration of quality and outcomes. The Index focuses on reimbursement, whereas behavioral health increasingly emphasizes evidence-based and measurement-informed care and moves beyond a simple parity construct. Including outcomes and measures of care quality would provide a fuller picture of behavioral health care in the United States.

At the end of the day, however, “We should be looking to advance beyond parity, a goal that is insufficient to meeting the mental health needs of Americans,” said Debbie Witchey, President and CEO of ABHW. “Parity is critically important, but we are striving for so much more—better outcomes and patients who can live full lives. Parity alone is an anemic goal. 

“We look forward to continuing to work with our health plan members and partners such as The Kennedy Forum to arrive at an ecosystem that provides quality health care delivery in all its forms.”