America’s Essential Hospitals has submitted comments supporting the Centers for Medicare & Medicaid Services’ (CMS’) proposal to apply provisions of the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA) to Medicaid alternative benefit plans, the Children’s Health Insurance Program (CHIP), and Medicaid managed care organizations. The MHPAEA requires insurance plans to provide comprehensive mental health and substance use disorder benefits that are equal to medical and surgical benefits. The proposal aims to ensure patients with the above-mentioned plans have access to these benefits.
The association also called on CMS to expand its proposal to all Medicaid and CHIP delivery systems, as the following would still be excluded:
- Medicaid fee-for-service plans
- CHIP enrollees covered by early and periodic screening, diagnostic, and treatment (EPSDT)
- Medicare managed care organizations (MCOs) that manage coverage for patients eligible for both Medicare and Medicaid
The association also urged CMS to provide robust guidance and oversight to states, particularly to ensure equitable provision of services across states and to confirm plans are not able to use administrative processes to deny services.
Finally, the association asked CMS to confirm that states will account for increased costs for these services in payments to managed care organizations. Actuarially sound payments are necessary for providers to guarantee access to Medicaid patients, particularly with the increasing number of Medicaid patients due to the Affordable Care Act.
Contact Zina Gontscharow, MPP, policy analyst, at zgontscharow@essentialhospitals.org or 202.585.0113 with questions.
