Asset 31

Parity

Our Perspective on Mental Health and Substance Use Disorder Parity

A Guide to MHPAEA​​

Welcome to ABHW’s comprehensive Mental Health Parity and Addiction Equity Act (MHPAEA) resource center. 

As the leading health plan association working to improve access and quality of care for mental health and substance use disorders, we have been at the forefront of and an advocate for mental health and substance use disorder parity for more than 15 years. 

ABHW was instrumental in drafting the legislative language of the initial MHPAEA of 2008, and our members have worked since then to implement parity for behavioral health services. ABHW remains committed to providing equitable coverage of mental health and substance use disorder treatment. 

What is MHPAEA?

MHPAEA, short for the Mental Health Parity and Addiction Equity Act, is a landmark federal law that requires the equal treatment of mental health and substance use disorder benefits in insurance plans. It is designed to eliminate disparities between mental health care and medical/surgical care and address our country’s growing need for mental health and substance use disorder services in our country.

The Recently Proposed MHPAEA Regulation

On July 25, 2023, the U.S. Department of Labor (DOL), the U.S. Department of Health and Human Services (HHS), and the U.S. Department of Treasury (DOT) – collectively, “the Tri-Departments” – released the Mental Health Parity and Addition Equity Act (MHPAEA) Notice of Proposed Rulemaking (NPRM) and Technical Release. While ABHW is committed to working with the Tri-Departments to enhance and refine regulations governing mental health and substance use disorder parity, we have several concerns with the currently proposed regulation. Our priority recommendations to the Tri-Departments on the proposed rule include:

The Tri-Departments propose to reinterpret the parity statute to subject medical management techniques, called Non-Quantitative Treatment Limits (NQTLs), such as prior authorization and concurrent review, to the quantitative tests that are currently applied to financial limits, called quantitative treatment limits (QTLs), such as copays and deductibles. ABHW requests that the Tri-Departments rescind the proposal to apply the Substantially All – Predominant Test and maintain the current NQTL testing requirements.

a. Independent Professional Medical or Clinical Standards: ABHW requests that the Tri-Departments interpret independent professional medical or clinical standards broadly and provide examples of standards that would meet the exception. ABHW also encourages the Tri-Departments to provide further clarity and examples of situations that would meet this exception and what is required documentation. 
b. Fraud Waste, and Abuse: ABHW requests that the Tri-Departments provide clear guidance specifying that health plans may use any reasonable methodology to determine how often the fraud, waste, and abuse data must be reanalyzed to show that the standard for reliance on the exception continues to be met.
c. ABHW Requests that the Tri-Departments Adopt Two Additional Exceptions: ABHW encourages the Tri-Departments to adopt an exception if a health plan applies a federal or state law to the design or operation of an NQTL and for factors designed to ensure the quality and safety of covered services.

The Tri-Departments’ enforcement powers do not permit them to require corrective action in the absence of noncompliance; ABHW, therefore, recommends that these sections be revised to apply only where the plan is unable to rebut the presumption of noncompliance that is triggered by a material difference in a required data measure.

View our comment letter here and a summary of our comment letter here.

Explore Our MHPAEA Resources

ABHW and MHPAEA In the News:
  • Behavioral Health Business: Eager for Parity Reform, Outpatient Mental Health Should Expect to ‘Step Up’ Care Quality
  • Mental Health Weekly: Proposed parity federal rule aims to boost MH coverage, increase service access
  • Behavioral Health Business: ‘It’s A Huge Deal’: Behavioral Health Stakeholders Praise New Mental Health Parity Rule
  • Bloomberg Law: White House Targets Insurers on Mental Health Law ‘Evasion’
  • Bloomberg Law: Mental Health Parity Proposal Reaches White House for Review
  • Bloomberg Law: Employers Await Mental Health Parity Help as Frustrations Build
  • StarTribune: Parity laws haven’t solved access to mental health care in Minnesota

How Our Health Plan Member Companies are Impacting Mental Health and Substance Use Disorder Parity 


Anthem Blue Cross Foundation (Elevance Health Foundation)
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Carelon/Carelon Behavioral Health, a subsidiary of Elevance Health
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Elevance Health
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Molina Healthcare
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MolinaCares Accord
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Optum
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Aetna
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Kaiser Permanente: Mental Health Scholars Academy
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Kaiser Permanente: 988 Collaboration
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Challenge

Substance use disorder continues to cast a shadow over the well-being and quality of life of countless Californians. Recognizing the pressing need for intervention, the Anthem Blue Cross Foundation has taken a significant step forward to address this issue.

Solution

The Anthem Blue Cross Foundation awarded $1.2 million in substance use disorder grants to five California-based organizations, including the California Health Collaborative in Fresno for Maternal Wellness to create a Perinatal Substance Use Task Force. This organization is dedicated to helping local mothers facing substance use disorder challenges.

Result

Through the grant, the California Health Collaborative for Maternal Wellness in Fresno, CA, has made significant strides in providing essential care and support to mothers who have limited access to resources or may be facing daunting barriers to recovery. The impact of their work resonates not just with the mothers they assist, but ripples through communities, fostering hope, health, and a brighter future.
 
The partnership between the Anthem Blue Cross Foundation and the California Health Collaborative in Fresno for Maternal Wellness is a testament to the power of compassion and collective action. Together, they are addressing the issue of substance use disorder and shaping a healthier and more resilient California.

Challenge

The United States was facing as of 2020 a dire opioid crisis, with over 107,600 Americans dying from drug overdoses in a year, and more than 75% of these deaths were attributed to opioids. The urgent challenge was to find effective treatment options for individuals with opioid use disorder (OUD). Despite the availability of FDA-approved medications for opioid use disorder (MOUD), they were underutilized. Many inpatient units relied on traditional withdrawal management protocols, putting patients at high risk for relapse, accidental overdose, and death due to decreased physical tolerance.

Solution

In 2018, Beacon Health Options (now Carelon Behavioral Health) and the Connecticut Behavioral Health Partnership (CT BHP) initiated the Changing Pathways program to promote MOUD, enhance outcomes for individuals with OUD, and save lives. The program’s three core elements included comprehensive education on treatment options, offering MOUD induction for interested individuals, and ensuring seamless aftercare for the continuation of MOUD. Peer specialists played a crucial role in the program, providing education and support both during the inpatient phase and up to 90 days after discharge. This peer-led approach aimed to establish trust and create a more personal connection with participants. In Changing Pathways, participants started MOUD during a withdrawal management episode and were discharged on a stable dose. The program facilitated their connection with community providers to continue MOUD treatment and follow a recovery plan.

Result

Changing Pathways successfully transformed practices, emphasized the importance of MOUD education, and implemented life-saving strategies that increased MOUD adherence, thereby making substantial strides in combating the opioid epidemic. Participant engagement with MOUD increased by 32%, ensuring more individuals with OUD received this critical treatment. There was a 12% reduction in readmissions to inpatient facilities within 30 days compared to traditional withdrawal management. Participants who remained MOUD adherent experienced significant reductions in the average number of behavioral health emergency department visits (54%), inpatient days (39.7%), and withdrawal management episodes (55.8%) in the 90 days following discharge. MOUD adherence in the 90 days following discharge led to a 74% reduction in overdoses, significantly improving the safety and well-being of program participants.
 
Learn more about Challenge Pathways here.

Challenge

The charitable arm of Health insurance provider Elevance Health saw the need to bridge the gap in health equity for individuals affected by mental health and substance use disorders.

Solution

Elevance Health Foundation provided a grant in the amount of $650,000 to Faces & Voices of Recovery to launch a digital app, The RecoveryNet. This app is designed to help facilitate connections and resource exchanges with others in the field from across the country and provide support through peer recovery specialists—individuals who are in recovery and use their own life experiences in ways that benefit others who facing similar experiences.

Result

The RecoveryNet app is a trusted companion on the road to recovery. With its wealth of resources at users’ fingertips, the app acts as a compass, helping individuals navigate the complex terrain of substance use disorders confidently and identify care for substance use disorders to prevent future relapses.

Challenge

Virginia faced significant health care disparities, including high rates of obesity, heart disease, and diabetes, with certain regions suffering from poor health outcomes due to limited access and funding for essential programs. Ensuring every citizen had access to the necessary health resources was a pressing concern.

Solution

The MolinaCares Accord, in partnership with Molina Healthcare of Virgina, launched Vision for Virginia initiative, investing over $1 million to support 30+ organizations focused on access to care, health-related social needs, behavioral health, food security, and maternal and child health of underserved populations across Virginia.

Result

The Vision for Virginia initiative by the MolinaCares Accord expanded access to essential healthcare services, promoted child development and literacy, created opportunities for disadvantaged youth, supported vulnerable groups, assisted families and youth, addressed social determinants of health, and promoted healthier eating habits. Notably, it provided vital support to single mothers returning to school, emphasizing the initiative’s holistic approach to improving community health and well-being. Through strategic investments, this initiative made a positive impact on Virginia’s residents and underscored the significance of corporate social responsibility in healthcare, ultimately strengthening the fabric of the communities it served.

Learn more about the Vision for Virginia initiative by Molina Healthcare here.

Challenge

As of September 2021, Washington faced a significant gap in meeting the mental health care workforce demand, with only 16.8% of the need being addressed. The COVID-19 pandemic further heightened the demand for behavioral health services, emphasizing the urgency for innovative solutions to expand access and support for those dealing with behavioral health challenges, particularly among the youth population.

Solution

In response to the pressing need, The MolinaCares Accord, in collaboration with Molina Healthcare of Washington, unveiled a $77,000 grant to SPARK, an organization committed to establishing a career pathway for youth to become certified peer counselors in Washington. The grant to SPARK specifically focuses on the identification, outreach, training, and placement of youth peer support. By empowering young adults who have overcome mental health challenges to become certified peer counselors, SPARK addresses the shortage in the mental health workforce and fosters a compassionate care environment. 

Result

The grant from MolinaCares is anticipated to significantly increase the number of youth peer counselors in the community. By providing support to the SPARK program, MolinaCares aims to create a more effective and compassionate care environment for Washingtonians living with behavioral health challenges. The program aligns with MolinaAccord’s mission to strengthen the youth peer support workforce and create a supportive environment for all youth seeking behavioral health support.

Challenge

Optum Behavioral Health, like many healthcare organizations, grappled with time-consuming clinical review processes that often left both providers and patients frustrated. Delays in verifying patient eligibility, assessing symptoms, and obtaining treatment approvals were common pain points. The challenges included lengthy waiting times, slow approval processes, and learning intricacies of the existing system for providers.

Solution

Optum Behavioral Health introduced the Smart Technology Authorization Request (STAR) system to address these challenges. STAR offers a streamlined and efficient approach to clinical reviews, making it a game-changer in the healthcare industry. Key features of STAR include Eligibility and Benefits Verification, Efficient Data Collection, Guideline-Based Review, Real-Time Approvals, and Optum Care Advocate Support, User-Centric Development, User Training, and User Access.

Result

The implementation of STAR has yielded remarkable results for Optum Behavioral Health and its members’ health outcomes:
 
  • Time Savings: The reduced hold times and streamlined processes have saved providers valuable time.
  • Faster Approvals: More than 50 percent of cases are now approved in real time, ensuring quicker access to treatments.
  • Resource Efficiency: STAR has decreased the time spent on clinical reviews by 30 percent, allowing staff to focus on more strategic tasks.
  • User Adoption: The self-paced training video and easy access have made it simpler for providers to adopt STAR.
  • Improved Patient Outcomes: Quicker reviews and approvals mean patients receive the necessary treatments faster, leading to better health outcomes.

Challenge

Aetna was looking to provide comprehensive and effective behavioral health care for its members while also accounting for members’ overall well-being, including the time and resources needed to achieve and maintain optimal health. Traditional approaches often do not address the complexity of behavioral health issues, including factors such as social determinants of health.

Solution

Aetna introduced the Aetna 360 Behavioral Health approach in May 2019, partnering with select behavioral health and substance use disorder treatment facilities. Under the Aetna 360 Behavioral Health program, partnering facilities and members have a dedicated 360 Care Advocate as their single point of contact with Aetna’s Behavioral Health team. These advocates work closely with Aetna 360 designated facilities to understand members’ needs, collaborate directly with members and caregivers during and after discharge, and they are supported by a multidisciplinary team at Aetna, including medical, and Resources for Living. Instead of focusing on standard time limits, Aetna prioritizes holistic care, comprehensive support, resource access, and collaboration for members and their families.

Result

The approach led to improved care coordination, enhanced member support, and positive feedback from both members and facilities. Aetna’s success with this approach has led to its expansion, with more partnering facilities implementing Aetna 360 Behavioral Health. This expansion ensures that more members can benefit from the program’s comprehensive and compassionate care, ultimately leading to better mental health outcomes for members.

Challenge

The United States faces a severe shortage of mental health professionals, with nearly half of the population living in areas lacking sufficient access to therapists and clinicians. This scarcity of mental health providers exacerbates the growing mental health crisis, leaving many individuals without the care they need.

Solution

Kaiser Permanente recognized the urgency of this issue and introduced the Kaiser Permanente Mental Health Scholars Academy to help address the shortage. This program supports its employees in becoming licensed mental health professionals by offering financial assistance and training. Under the program, Kaiser Permanente takes employees aspiring to become mental health professionals and provides financial support for up to 75% of their tuition at a master’s program. Participants also have opportunities to receive training within Kaiser Permanente settings, enabling them to meet their degree requirements.

Result

The Academy has successfully transitioned employees into mental health careers, addressing diversity in the workforce and providing supervised clinical experience for licensure. Participants receive both pay and benefits during training, fostering quicker transitions into full-time roles. The program has enhanced the mental health workforce and helped improve access to high-quality mental health services.
 

Challenge

Mental health crises often occur without warning, leaving individuals in desperate need of immediate care. The challenge lies in seamlessly integrating the public mental health crisis services with clinical care, ensuring individuals receive the support and treatment they require in these critical moments.

Solution

Kaiser Permanente recognized the need for collaboration and has taken significant steps to bridge the gap between immediate crisis response and ongoing mental health care. They have actively worked with state officials to coordinate follow-up appointments for members who contact the 988 Suicide & Crisis Lifeline or their local crisis line. Additionally, they’ve increased the number of behavioral health consultants in primary care, acknowledging that crisis response and clinical care are interconnected and cannot function in isolation.

Result

The successful rollout of the 988 Suicide & Crisis Lifeline demonstrates how policy improvements can enhance integrated crisis care. The 988 Suicide & Crisis Lifeline has opened new doors for mental health support, and it is essential that these doors lead to a compassionate and connected network ready to provide assistance whenever needed.