Parity

The Wellstone-Domenici Parity Act went into effect on January 1, 2010.  Insurance companies must comply with the law on that date even though federal regulations that clarify what the law intends had not been published.  The Interim Final Rule/regulations (IFR) were issued February 2010 and generally apply to group health plans and group health insurance issuers for plan years beginning on or after July 1, 2010.

For additional information on parity implementation visit www.mentalhealthparitywatch.org.  The APA is a member of the Parity Implementation Coalition (PIC) and manages the website.

Member note:  APA Members may access OHSF assistance for parity or other practice management issues by calling the HelpLine at 800.343.4671 or by sending an email to hsf@psych.org. 

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    The Parity Act & Regulations:

    ·         MHPAEA  (full text of the Mental Health Parity and Addiction Equity Act of 2008 from CMS)

    ·         Interim Final Rule (IFR) (from the Federal Register)

    ·         Summary of the Act, prepared by APA's Office of Healthcare Systems and Financing

    ·         DOL/EBSA Fact Sheet on MHPAEA

    ·         FAQs About Affordable Care Act Implementation Part V and Mental Health Parity Implementation

    ·         Congressional letter on parity

     

    Compliance and Enforcement:

    ·         Analysis of the 8 most common compliance issues  [Patton-Boggs/PIC]

    ·         Medical Necessity/Plan Document Disclosure FAQ posted by DOL on MHPAEA, scroll to Q10.

    ·         Analysis of the scope and range of services between common medical and behavioral disorders [Milliman, December 2010]

    ·         Agencies create an enforcement Safe Harbor for plans/issuers until final rules are issued under which the Agencies will not take enforcement action against a plan or issuer that divides its benefits furnished on an outpatient basis into two sub-classifications for purposes of applying the financial requirement and treatment limitation rules under MHPAEA: (1) office visits, and (2) all other outpatient items and services.

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    APA     responds as BCBS-FL Terminates Mental Health / Substance Use Disorder Provider Network [posted 09.02.2011]

    APA President's March Video on Mental Health Parity

    APA requests State Insurance Commissioners take action against health plan policy that prohibits use/billing of general E/M codes (99xxx) by psychiatrists as a violation of the parity law. For more information contact the APA's Office of Healthcare Systems & Financing at hsf@psych.org. [posted 03.07.2011]
     
    BCBS-IL has made changes to the behavioral health services preauthorization requirements    , effective January 1, 2011.
    APA and Illinois Psychiatric Society raise concerns with BCBS-IL     about new behavioral health services (BHS) prior authorization requirements, effective January 1, 2011.