FOR IMMEDIATE RELEASE
April 6, 2015
NAMD Response to New Mental Health Parity Regulations
Today's release of draft regulations regarding mental health parity and addiction equityis an important step in an ongoing conversation about how best to integrate behavioral health treatment into the rest of the health care system.
In the historical absence of effective parity rules and regulations, Medicaid has quietly become the largest payer of mental health services in the country, in part because other payers have been able to shift these costs onto the safety net. Medicaid Directors are hopeful that parity ultimately helps to level the playing field, which would allow more people to get the care they need at the right time, and ultimately reduce future reliance on Medicaid. This should have the effect of strengthening the safety net for those who need it the most, but could take many years to fully realize.
In the meantime, Medicaid programs are increasingly turning to improving the delivery system, through managed care, ACOs, patient centered medical homes and a variety of other approaches to better coordinate care for people with a variety of health care needs. In fact, NAMD's recentOperational Surveyindicates that integration of physical health and behavioral health is one of the top priorities of Medicaid Directors nationwide. The draft regulation certainly helps to underscorethe work that has already been taking place at the state level to integrate care for those with behavioral health needs.
But in the short term, this rule will result in additional costs for Medicaid programs. Because of decades of insufficient investments from other payers, approximately 30 percent of all Medicaid dollars are spent on individuals with behavioral health needs. These regulations will lead to increased coverage of (and therefore spending on) behavioral health services for Medicaid beneficiaries in managed care or other capitated care models. While it is hard to know what the bottom line impact of this will ultimately be, the regulations doassume that this will cost state governments $150 million in the near term.
It is also important to note that there are a number of other long-standing barriers to improved access to behavioral health services in Medicaid. These include the statutory prohibition on coverage for adults in an institute for mental disease (IMD), as well as regulatory barriers to the effective sharing of substance use treatment information as a part of 42 CFR Part 2. While the Administration is still working on addressing some of these issues, others can only be fixed by an act of Congress, and all of them are described in NAMD'srecent paperon supporting state behavioral health reforms.
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