Parity & Compliance
MENTAL HEALTH PARITY & ADDICTION EQUITY ACT (MHPAEA)
The Mental Health Parity & Addiction Equity Act was signed into law over 10 years ago. Still, mental health parity remains a challenge for a majority of the States.
If insurance agencies offer coverage for substance use and mental health disorders (“behavioral health”), the parity law requires that access to and treatment for both are provided on a par with those for physical health conditions.
SAE Parity Experience
- Working directly with attorneys general offices to assess and enforce parity compliance on the part of health insurance companies doing business in their states
- Consultations with state regulators about ways to evaluate parity compliance by health insurers
- Parity compliance assessments on behalf of health insurance clients responding to regulator questions or concerns
- Parity compliance assessments on behalf of self-insured employers proactively responding to provisions contained in the Consolidated Appropriations Act of 2021 (CAA) that require employers to demonstrate parity compliance
HOW THE SAE PARITY COMPLIANCE TEAM CAN HELP
The Office of Attorneys General
- Providing assistance in gathering both pertinent information and data metric solutions to evaluate the current degree of Parity compliance of a Health plan and its behavioral health vendor – a Discovery phase
- Functioning as an external parity compliance administrator, assessing the Health Plan’s movement toward compliance as defined by terms of a settlement, and
- Functioning as an external reviewer of a Health Plan’s internal parity compliance efforts either voluntarily initiated by the Health Plan or mandated by a settlement derived from litigation
Insurance Commissioners
- Guiding them in forming the standards and requirements to which Health Plans must demonstrate compliance
- Collecting data and analyzing health plan policy and practice, as they relate to the requirements of the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA)
- Utilizing a sophisticated data metrics approach to measure compliance against both Quantitative Treatment Limitation (QTL) and Non-Quantitative Treatment Limitation (NQTL) Parity requirements, and
- Determining the information and data needed to begin an overview of a Health Plan’s structure and design
Health Plans
- Providing external parity compliance monitoring of their efforts to meet parity requirements
- Helping Health Plans organize their data, and
- Refining their approach and putting a robust structure in place to ensure parity compliance is not only met, but also sustained
As an experienced State-selected Independent Compliance Administrator (ICA), SAE effectively measures and evaluates health plan compliance with federal parity legislation.
SAE’s parity compliance strategy encompasses four key integrated monitoring aspects: Benefit Plan Design (Quantitative Limits), Network Compliance, Utilization Management / Utilization Review (Non-Quantitative Limits), and Data Reporting.
SAE reviews cost-sharing, visit limits, comparability of utilization review processes & necessary reforms, inter-organizational structure and culture to support Parity Compliance, medical necessity/fail-first criteria, adverse determination process and communication, internal and external appeal processes, and network adequacy and comparability.
SAE’s experts utilize substantial data metrics to identify and evaluate the impact of behavioral health service and system changes including:
Spend and utilization changes, utilization review rates, medical necessity denial rates, internal appeal/reversal rates and external appeal/reversal rates across all levels of care to measure sustainability of change and high-level comparison of utilization review/denial rates and trends for behavioral health services versus those for physical health services
SAE Webinar Presentation – Mental Health Parity and Addiction Equity Act (MHPAEA): Measuring and Ensuring Compliance, 2016
SAE Parity Series Podcasts
The SAE Parity & Compliance Team
Alex Hutchinson, MBA, Maria Messina, PhD, and Brian Baldwin, LCSW, each bring a unique set of expertise to the team, providing an in-depth, robust, interdisciplinary approach to parity compliance.
Adept and well-versed in the nuanced intricacies of the Federal Parity Act and new rules, the SAE Team provides a swift and responsive approach to the analysis and translation of the complex regulations, laws, and policies for stakeholders.
