Mental Health Parity and Addiction Equity Act Webinar


Welcome to this presentation on the
state of Colorado’s mental health parity and addiction equity act analysis
performed by the Colorado Department of Health Care Policy and Financing. The
Department of Health Care Policy and Financing administers Health First
Colorado (Colorado’s Medicaid Program) and the Children’s Health Insurance Program
in the state of Colorado the mission of the department of healthcare policy and
financing also referred to as the department is to improve healthcare
access and outcomes for the people we serve while demonstrating sound
stewardship of financial resources in this presentation I will provide a brief
overview of the health first Colorado Colorado’s Medicaid program delivery
system I will also provide an overview of the delivery system for children’s
health insurance program known as child health plan plus or CHIP plus in
Colorado I will then talk about the federal laws
and requirements surrounding the mental health parity and addiction Equity Act
also referred to as parity from there I will discuss the department’s internal
process for conducting our analysis in determining compliance with parity
finally I will discuss how to provide feedback to the Department regarding
parity for health first Colorado most physical and behavioral health benefits
are administered through the state’s Medicaid managed care system the
department administers the community behavioral health services program a
statewide program that provides comprehensive and until health and
substance use disorder services to most health first Colorado members members
received these services through an assigned behavioral health organization
known as a BHO there is one BHO serving each of the state’s five regions in
addition to adho most members are enrolled with a primary care case
management entity known as a regional collab
of care organization or Rico the Rico’s provide care coordination to members and
also help members find community services in their area most members
receive their physical health services through their Rico in certain areas of
the state members can choose to receive their physical health services through a
full risk managed care organization known as a MC EO number served by n Co
received their behavioral health services through ABA Jo there are 2 MC
owes serving roughly a hundred and thirty thousand members the state plan
is the document the department uses to describe services available through
health first Colorado and CHIP flus when the state of Colorado chose to expand
health first Colorado coverage under the Affordable Care Act in 2014 it did so
through an alternative benefit plan or ABP members who became eligible for
health first Colorado through the expansion are covered by the EBP which
offers the same benefits as the state plan numbers that are covered by the ABP
receive services through the managed care system members who need specialized
care beyond state plan services may qualify for a home and community-based
services waiver referred to as HCBS members and an HCBS waiver may also be
enrolled in a managed care plan Colorado’s CHIP plus plans are
classified as fully comprehensive MCO s which means they offer both physical and
behavioral health services there are five chip plus MC OHS in the state Paul
Wellstone and pete Domenici mental health parity and addiction Act of 2008
is the federal law that requires this analysis the final rule published in
March 2016 can be found in the Federal Register at 42 CFR parts 438 444 56 and
4:57 in 2013 guidance was provided to the states from the Centers for Medicare
and Medicaid Services or CMS that confirmed the application of parity to
health first Colorado and CHIP plus plans each state must publish an
analysis showing compliance with the rule by October 2nd 2017 in states where
both physical and behavioral health services are not offered through a
comprehensive MCO like Colorado the state must conduct the analysis to show
compliance with the parity rule as Colorado’s Chubb plus plans are fully
comprehensive and provide both physical and behavioral health services each MCO
was responsible for conducting their own parity analysis and reporting the
results to the department the following two slides from CMS provide an overview
of the requirements for parity parity requires health plans to ensure that
financial requirements and treatment limitations applicable to mental health
or substance use benefits referred to as MH sed benefits are no more restrictive
than the predominant financial requirements and treatment limitations
applied to substantially all medical and surgical benefits covered by the plan
financial requirements include co-payments coinsurance deductibles and
out-of-pocket maximums treatment limitations here are referring to
quantitative treatment limitations which includes limits on scope or duration of
benefits expressed numerically like visit limits while not on this slide it
is important to note that parody also requires that an aggregate lifetime or
annual dollar limit cannot be applied to image s UD benefits unless it applies to
at least one third of medical and surgical benefits charity also requires health plans to
not impose a non-quantitative treatment limits as me in QTL on image su d
benefits unless the processes strategies evidentiary standards and other factors
used in applying in qtls are comparable to and applied no more
stringently than the processes strategies evidentiary standards or
other factors used to apply the ink ETL to medical and surgical benefits in the
same classification in qtls are limits on the scope or duration of benefits
that are not expressed numerically such as medical management standards or fail
first policies what this line means is that while in qtls may be applied to a
behavioral health benefit the rationale for applying the in QTL must be similar
to the rationale for applying in in qcl to a physical health benefit the Inc ECL
must be applied no more stringently to a behavioral health benefit than a
physical health benefit while the law does strive for equal
access to behavioral and physical health services it does not require all
behavioral health services to be provided by the state the parity rule
does not require a MCO or BHO to provide any image su d benefits beyond the scope
of its contract this means that this rule does not require Colorado’s NCOs
and Pho s to provide a image SED benefit that is not found in their contracts the
rule also does not require a MCO or VA Joe that does provide image SED benefits
to provide additional image su d benefits because of the rule federal
regulations also do not require any specific image SED benefits to be
provided through an ADP this slide from CMS shows the steps to the department
followed to conduct the parity analysis for health fairs Colorado the department
identified the benefit packages for which the parody table applies to find
the benefits and conditions for which parody applies to mats the benefits to
the four classifications identified and analyzed financial requirements
quantitative treatment limits and aggregate lifetime and annual dollar
limits identified and analyzed in qtls analyze the availability of information
and finally document our determination of compliance for public posting in
order to conduct the analysis the Department held weekly meetings with an
internal work group comprised of subject matter experts in programs policy
benefits long-term services and supports finance and data analytics to work
through each step in requirement for compliance the chip + NCOs were
responsible for conducting their own analyses and also follow these steps the
first step in the parody analysis was to identify the affected benefit packages
the final rule states that parity applies to members covered by
healthfirst Colorado MCO the ABP and Chip Plus even though the MCO s only
cover a hundred and thirty thousand members the department wanted to ensure
similar access for all members the next step in the department’s analysis was to
define the benefits and conditions covered under parity the department uses
standard definitions reflected in state rules and regulations a behavioral
health benefit treats a mental health or a substance use disorder condition a
medical surgical benefit treats a medical condition that’s not a mental
health or substance use disorder condition after the department defined
the benefits and conditions affected by parity the Department mapped each
benefit to the for benefit classifications identified by CMS
inpatient outpatient emergency and pharmacy the benefit map for health
first Colorado services can be found on page 4 of the analysis per CMS guidance
ABP benefits must be compliant with parity regardless of whether the
benefits are administered through fee-for-service or managed care as
mentioned previously members covered by the ABP receive their services through
the managed care system and the AVP benefits mirror the state plan benefits
therefore the department has determined the AVP is compliant with parity through
the benefit mapping process the department has determined that all
long-term services and supports administered through HCBS waivers fall
into the medical surgical benefit category the department was required to
analyze any financial requirements quantitative treatment limitations and
aggregate lifetime and annual dollar limits that would restrict access to a
MH s UD benefit more so than a medical surgical benefit the community
behavioral health services program does not utilize any of these
limitations 4mh sed benefits therefore the department is compliant
with this parity requirement to show compliance of parity states were also
asked to identify and analyze in qtls used in their Medicaid programs this
required the department to analyze as written and and operation any processes
strategies evidentiary standards or other factors used in applying an in QT
L to image SED benefits and each classification to ensure they are
comparable and applied no more stringently than the processes
strategies evidentiary standards or other factors used in applying a in QT l
to medical surgical benefits in the same classification through the final parity
rule guidance from CMS and technical assistance provided to the states the
department identified 5 in qtls that are applied across benefits prior
authorization retrospective review network provider admission establishing
charges and concurrent review the department divided each in QTL into each
of the four benefit categories inpatient outpatient emergency and pharmacy and
provided questions to the MCO s and the be a chose to review and analyze how and
when the in qtls are applied the department also had to
review and operationalize the availability of information regarding
image SED benefits there are two requirements under this section first
the criteria for medical necessity determinations must be provided upon
request to members potential members and contracting providers the department is
currently working with its managed care plans to determine the best way to make
this already public information more easily accessible second the reasons for
any denial of reimbursement or payment of a NHS UD benefit
be made available to numbers this is accomplished through the new managed
care regulations the department has created a standard notice of adverse
benefit determination for the be a chose to use when denying a service or payment
for a service this notice contains the reasons for the denial and is sent
automatically to members the last step of the analysis is documentation the
department’s final analysis was posted on its website on October 2nd 2017 it
can be found under the regulatory resource center along with this
presentation and other parody related information this analysis includes the
required elements for health first Colorado ADP and CHIP plus plans as
previously mentioned Colorado’s chip plus MCO plans are fully comprehensive
which means they provide both image sed and medical/surgical benefits for the
final rule each MCO was responsible for conducting its own parity analysis with
the department making the final compliance determination moving forward
here are some next steps the department will take to ensure ongoing compliance
with parity CMS requires each state to submit a chip plus state plan amendment
to demonstrate continued compliance of parity the department is currently
undergoing this process for submission by the end of this fiscal year June 30th
2018 the department has posted responses to some frequently asked questions on
its website if you would like more information on the parity rule where you
can find information on your benefits or other questions please visit the
regulatory resource center on the website for more information if you have
questions or comments regarding parity the department has created a web form to
submit feedback directly to the department this Web form can be found in
the department’s regulatory Resource Center under mental health parity
to submit feedback please visit www.hp.com/recycle a periodic frequently
asked questions for posting on the website we thank you for your interest
in parity

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