It's getting harder and more expensive for many people to get behavioral health care, according to Milliman Inc.'s report, "Addiction and Mental Health vs. Physical Health- Widening disparities in network use and provider reimbursement."
The Bowman Family Foundation engaged Milliman to use third-party administrative claims data to assess non-quantitative treatment limitations associated with behavioral health care services. The analysis, covering 37 million employees and dependents, reflects that conditions have worsened since a similar study was published two years ago.
"Based on the robust sample of commercial PPO plans, significant disparities continue to exist between medical/surgical providers and behavioral health care providers with respect to out-of-network utilization levels, and provider in-network reimbursement rates," the authors write. "Behavioral providers have lower reimbursement levels and higher out-of-network use. Most of these differences have increased since our prior report."
Two of the report's top findings:
- From 2013 to 2017, the disparity between how often behavioral inpatient facilities are utilized out of network relative to medical/surgical inpatient facilities has increased from 2.8 times more likely to 5.2 times more likely, an 85 percent increase in disparities over five years.
- Average in-network reimbursement rates for behavioral health office visits are lower than for medical/surgical office visits (each as a percentage of Medicare-allowed amounts), and this disparity has increased between 2015 and 2017. As of 2017, primary care reimbursements were 23.8 percent higher than behavioral reimbursements, which is an increase from 20.8 percent higher in 2015.
"Our findings of payment disparities in this updated analysis suggest that plans should conduct a detailed assessment of provider payment rate methodologies to assess whether there is compliance with the Mental Health Parity and Addiction Equity Act MHPAEA and its NQTL non-quantitative treatment limitation regulations," the authors write. "If a plan finds that it is not parity-compliant in this area, it should increase its payment levels to behavioral health care providers.
That increase in payment rates could also lead to an increase in the desire of behavioral health care providers to join the health plan's provider network. This, in turn, could then lead to higher use of in-network services for behavioral health care, thereby addressing the other potential NQTL compliance issue of disparate out-of-network utilization rates between behavioral and medical/surgical health care."
In the press release announcing the publication of Milliman's report, a coalition of leading behavioral health organizations also recommended several key initiatives "that could make a large impact immediately:"
- On Nov. 12, the initiative "The Path Forward for Mental Health and Substance Use" was announced by the National Alliance of Healthcare Purchaser Coalitions, the Meadows Mental Health Policy Institute, the American Psychiatric Association Foundation's Center for Workplace Mental Health and the American Psychiatric Association. This is a five-year implementation plan that will partner with health plans (essential to helping address this public health crisis) and other key stakeholders to drive change.
The Five Priority Strategies that will be executed are to improve network access for behavioral health specialists; expand use of collaborative care to integrate behavioral health into primary care; implement measurement-based care to improve quality and outcomes; expand tele-behavioral health; ensure mental health parity compliance.
- Federal and state parity regulators should increase their oversight in several key areas: (a) require health plans to provide comparative quantitative data covering parameters such as out-of-network use rates, reimbursement rates, denial rates, pre-authorization requirement rates, and concurrent review rates, and (b) specify detailed definitions and instructions for these comparative data analyses by using tools similar to the Model Data Request Form currently being used by the National Alliance and employers ("MDRF").
- The coalition urges any insurer that believes the disparities in the current Milliman report are not reflective of its plans, or that its plans have improved since 2017, to publicly release data for its plans obtained by using the MDRF. The definitions and methodology in the MDRF are consistent with definitions and methodology used in the analysis of the current Milliman report, and are used by the National Alliance.
- Consumers and others are encouraged to visit www.ParityTrack.org to track parity legislation in all 50 states, and www.DontDenyMe.org, which offers education about consumer rights under the Federal Parity Law.
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