Mental Health Parity - Implementation, Best Practices

by Ronal E. Bachman FSA, MAAA, President & CEO, Healthcare Visions, Inc.


Mental illness causes more days of work loss and work impairment than many other chronic conditions such as diabetes, asthma, and arthritis. [1] Approximately 217 million days of work are lost annually due to productivity decline related to mental illness and substance abuse disorders, costing Unites States employers $17 billion each year. [2] In total, estimates of the indirect costs associated with mental illness and substance abuse disorders range from a low of $79 billion per year to a high of $105 billion per year (both figures based on 1990 dollars). [3]

To optimize the corporate value when implementing the Mental Health Parity and Addiction Equity Act (MHPAEA), health plans should review their benefits design and the various ways mental health services are accessed, delivered, and paid for.   The MHPAEA Interim Final Ruling (IFR) was produced February 2, 20109, but questions remain and legal interpretations will take years to settle. IFR follow up clarifications will probably stretch into 2010. The following is offered as help and support for employers wanting to implement best practice suggestions that are likely to provide the greatest corporate effort for creating a healthy workforce. 
 

1. Equalize benefit structures per MHAEA Parity Requirements — Equalize all financial requirements and treatment limitations for mental health with medical and surgical benefit designs.
2. Assure Adequate Access to Hospital, Office Visits, and Other Access Points of Care – for mental health benefits this includes, hospitalization, partial hospitalization, residential care, and office visit services.
3. Eliminate and office visit limits and/or hospital day limits on mental health services – Most health plans do not have limits on office visits for medical care. MHPAEA does not allow restrictions on mental health treatments to be more limited than provided to substantially all other medical/surgical benefits. There are not usually annual or other limits on the number of office visits for medical care.   This would mean that mental health office visits must be the same. 
   
4. Use common deductibles and Maximum Out-of-Pocket (MOOP) cost-sharing – Use a common deductible and a common MOOP cost sharing features in health plan designs. That is, use a single deductible where all cost-sharing is applied whether or not the covered claim is for mental health or a medical/surgical claim.
   
5. Equalize coinsurance – for plans using a coinsurance benefit design, the predominant coinsurance percentage covered by the plan should apply to mental health claims. In the past, some plans paid 80% coinsurance on medical/surgical claims and 50% for mental health. Under this example, to comply with MHPAEA the 80% coinsurance would also apply to mental health claims. 
   
6. Equalize office Co-payments – for plans with co-payments the psychotherapy office copayment should be the same as the predominant office copayment under the plan.   In general, this is likely to be the same as that applied to primary care physicians.
   
7. Improve coordination between Disease Management programs, general medical care, and mental health services — Employers should require their disease management vendors, as part of their regular practice, to periodically screen all patients enrolled in their respective programs for common behavioral health conditions, and coordinate care with other providers as indicated.
   
8. Encourage Preventive Mental Healthcare and Early Intervention – Remove stigma and encourage plan members to seek mental health support for high stress and depression. Prevention and early intervention can avoid more costly illnesses generated from untreated conditions.
   
9. Address the High-Risk of Co-Morbidities — Primary care physicians and other health providers under the plan should be alert to and screen for depression and other common mental health conditions among individuals with chronic medical illnesses. Patient left untreated for depression are less able to maintain compliance with medications and other provider ordered treatments.
   
10. Referrals to the Mental Health Providers — Primary care physicians are many times the first to identify depression and other emotional conditions of their patients. Referrals from primary care to mental health providers should be encouraged to effectively diagnose a patient’s condition and maximize patient care.
    
11. Collaborative Care — Use a collaborative care model to address the needs of patients with mental illnesses who are also receiving treatment in primary care.   Collaboration on care and treatments by all providers of care should follow accepted professional standards and courtesies.
    
12. Assure Equal In-Network and Out-of-Network Access –Patients in need of mental health care should have access to quality providers when seeking either in-network or out-of-network services.
    
13. Equalized benefits for Out-of-Network Mental Health Services – OON benefits cannot have more restrictive financial requirements than medical/surgical benefits. If OON medical/surgical benefits are provided, OON mental health benefits must be provided on an equal cost-sharing basis.
    
14. Annual Review of Mental Health Treatments — Annually review mental health treatments and make plan changes to reflect new treatments and procedures that should be added to the plan’s benefit design.
    
15. Don’t play games looking for loopholes – the corporate value to providing mental health coverage under MHPAEA is now well established. MHPAEA states clearly that there are to be “no separate cost sharing requirements that are applicable only with respect to mental health or substance use disorder benefits.”

During the past few years employers have focused on general health quality and benefit design improvements to better engage plan members. Many employers have shown the way to better health with mental health. Now is the time to recognize the science, experience, and the legislative standard to equalize mind and body treatments and financial support in a comprehensive approach to providing improved worker health status and optimize the corporate value of its human capital.