Mental Health Parity – A Guide to Implementation:
PART I Checklist

by Nancy C Everitt, MBA
Published 07.28.2010 Scientific Cowboys

Overview: Implementation is underway for the Interim Final Rule (IFR) for the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA).

The MHPAEA requires parity between mental health/substance abuse (MH/SA) and medical/surgical benefits in terms of financial limits and treatment access for group health plans of 50 employers or greater including self insured employers subject to ERISA.

This means that benefit structures may not be different between mental health/substance and physical medicine services, if the plan benefits include MH/SA services. Parity will increase access to MH/SA services and may advance the medical home models.

This article is the first in a series on “Mental Health Parity Implementation and Network Impact”. We will explore how group plans are preparing to meet the need for increased services, potential strains on existing networks and operational details that are required for effective implementation.

Note: IFR regulations are not applicable to Medicaid Managed Care Plans. CMS will provide separate regulations for Managed Medicaid; however Managed Medicaid is still subject to the law. Medicare Advantage Plans are not impacted unless it is an employer sponsored group health plan. Small employers with less than 50 employees are exempt.

Impact and Implications of Parity...

For some, the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008 is long over due and will increase access to mental health/substance abuse services beyond benefit existing caps and standardize access processes similar to other forms of care. For others, the cost of parity is concerning as well as the operational implications to ensure compliance may require some intensive operational changes.

We will explore neither the pros nor the cons of parity, but will focus solely on the facts of implementation and how group health plans will be impacted along with the strategies for operational implementation and network refinement.

It is important to note that MH/SA benefits are not mandated for inclusion in plan benefits, a plan may opt to cover some but not all services, however if the benefit is offered parity must exist with physical health benefits.

Impact will be significant, take the time to review the impact and implications of parity on all facets of operations and benefits.

Included below is a checklist to utilize to gauge your organization’s efforts and/or plan strategy. In upcoming articles, we will delve into specific implementation and planning strategies.

Print and discuss this checklist internally.

Scientific Cowboys Mental Health Parity Checklist Items: Directions: Rate your organization on a scale of 1 to 10, with 10 as the highest level of readiness. Impacted Plan: Our organization has fully assessed if we are an impacted plan and have a good understanding of the requirements of the Interim Final Rule. Planning Team: Our organization has created a multi-disciplinary team and Champion which are accountable for leading and implementing the requirements of the IFR of the MHPAEA. Timing Requirements: Our organization has implemented or is in process of implementing parity effective on the first day of the plan year beginning or renewing on or after July 1, 2010. Benefit Requirements: Our organization has assessed the six classifications of benefits and identified how parity will be achieved for treatment limits and financial requirements defined by the regulations for each of the six classifications: Inpatient In-Network Inpatient Out-of-Network Outpatient In-Network Outpatient Out-of-Network Emergency Prescription Drugs Operational Implications: Our organization has assessed and implemented changes to the following operational areas that may be impacted by parity: Universal Definition for Inpatient, Outpatient and Emergency for all services Benefit Design Co Pay and Deductible Merge Medical Management and Medical Necessity Formulary Design Methods to determine UCR and Rates Provider Directories Provider Manuals Network Access Adequacy Network Disruption Member Services Provider Relations Claims Payment IT and Web Communication: Our organization has communicated changes to all stakeholders internal and external and published relevant materials to key access points. Training: Our organization has trained internal and external stakeholders necessary for implementation. Compliance: Our organization has established a process for monitoring and controlling compliance and changes with the MHPAEA. Documentation: Our organization has supporting documentation and bread crumbs documenting implementation to support future development and or audit. Closure: Our organization has conducted an evaluation of the MHPAEA changes and validated that the IFR requirements are documented and fulfilled.

SCORING:

0-30: Take Action! If your organization is an impacted plan, action is necessary. Seek outside assistance if your team does not have the focus or resources to lead this charge. A Champion with authority is necessary to move this endeavor forward.

31-60: On the Move. Your organization is on track; ensure that Senior Leadership has provided the appropriate empowerment to move forward. Avoid rabbit holes. Seek assistance if your team cannot achieve the objectives timely.

61-80: In the Lead. Your organization has an effective process in place and is moving toward compliance. Stay focused and on track. Don’t lose momentum.

81-100: Approaching the Finish Line. Great work, your organization is setting the bar and has lowered organizational risk through compliance with the MHPAEA. Tic and tie at this juncture, ensure that documentation exists and closure is completed with an effective monitoring and controlling process in place.

SUMMARY:
To achieve compliance with the MHPAEA there is a great deal of assessment, modification and refinement occurred. There is a cultural shift and an alignment required to achieve MH/SA parity.

Utilize the Checklist above to determine where your organization is along the compliance and implementation process. Good project management structure is included in the Checklist to minimize risk and oversight.

 

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About the Author:

Nancy C. Everitt, MBA is the President and CEO of HEOPS, Inc. and Editor in Chief of Scientific Cowboys. Ms. Everitt is lead strategist to Clients’ on the design and fulfillment of patient access solutions such as network development, complex contracting, on the fly call centers, data analytics, disruption analysis and mapping. Ms. Everitt has been involved in the strategy of each engagement and provides significant perspective on industry best practice. She has honed core processes and works with a talented team of professionals capable of recruiting full networks in 90 days or less.

With more than 20 years of progressive senior level management experience in the healthcare, technology, and broadcast industries, Ms. Everitt brings diverse leadership, client relations, and operational skills to the greater team and Client engagements. Prior to founding HEOPS, Ms. Everitt’s skills were honed with key organizations such as Quorum Healthcare, HCA Healthcare, LifePoint Hospitals, Inc. and several start-up technology and healthcare companies.

In addition to serving as Editor in Chief on Scientific Cowboys, Ms. Everitt is a frequent contributing writer to the publication sharing real world advice and operational insights on process and performance improvement. Questions on this article may be addressed directly to neveritt@heops.com.