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CMS Seeks Feedback on Mental Health Parity in Medicaid, CHIP

The Centers for Medicare & Medicaid Services (CMS) Center for Medicaid & CHIP Services (CMCS) solicits comments on processes for assessing compliance with mental health parity and addiction equity in Medicaid and the Children’s Health Insurance Program (CHIP).

The solicitation chronicles Medicaid and CHIP mental health and addiction parity regulations, guidance, and technical assistance, focusing on Medicaid managed care organizations, and cites recent studies indicating individuals still struggle to access these services.

The request then reviews current processes for ensuring compliance with parity in Medicaid and CHIP, including those for Medicaid managed care arrangements, carved-out benefits, CHIP requirements, and Medicaid alternative benefit plans.

In light of recent updates and proposed regulatory changes for mental health and addition parity in private sector plans, as well as concerns raised by various affected parties regarding barriers to care, CMCS seeks additional information on ways to assess parity compliance in Medicaid and CHIP. Issues for feedback include:

  • Documentation model formats and templates for compliance with parity requirements.
  • Key issues in parity compliance for nonquantitative treatment limitations (NQTLs), including classifications of NQTLs and high-priority NQTLs.
  • Useful measures and datapoints in parity compliance.
  • Mental health conditions and substance use disorders with significant barriers to care, as well as those at risk for exclusion in compliance reviews.

Comments are due Dec. 4 via email to

Contact Senior Director of Policy Erin O’Malley at or 202.585.0127 with questions.


About the Author

Julie Kozminski is a senior policy analyst at America's Essential Hospitals.

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