Mental Health Parity
On March 29, 2016, the Centers for Medicare & Medicaid Services (CMS) issued the Medicaid Mental Health Parity Final Rule (Parity Rule) to strengthen access to mental health and substance use disorder services for Medicaid beneficiaries. The Parity Rule was intended to create consistency between the commercial and Medicaid markets. Specifically, the Medicaid Parity Rule includes the following compliance requirements:
- Aggregate lifetime and annual dollar limits
- Financial requirements (FR) such as copayments, coinsurance, deductibles, and out-of-pocket maximums
- Quantitative treatment limitations (QTLs), which are limits on the scope or duration of benefits that are represented numerically, such as day limits or visit limits
- Non-quantitative treatment limitations (NQTLs), which are limits on the scope or duration of benefits in processes, strategies, and evidentiary standards, or other factors, such as medical management standards or provider network admission standards
- Availability of information
A key objective of the Medicaid Parity Rule is to ensure that restrictions or limits are not more substantively applied on mental health and substance use disorder services as compared to medical surgical services. Parity compliance requires that the analysis of imposed restrictions and limitations is conducted in the four benefit categories: inpatient, outpatient, prescription drugs, and emergency services. Further, the Medicaid Parity Rule requires that parity is applied across delivery systems and includes long-term care services and supports.
Compliance Plan
DHCS submitted the State Compliance Plan to CMS to demonstrate compliance with the Parity Rule by the implementation deadline of
