Managed Healthcare Executive - March 2009 - (Page 24) { HEALTH MANAGEMENT } “The basics are very clear, in terms of its parity for nancial limitations and treatment limits,” says Pamela Greenburg, president of the Association of Mental Health and Behavioral Services, a trade group representing managed behavioral health organizations. “Where it becomes less clear is: what do you compare these bene ts to? What is the de nition of ‘predominant’ and what GUIDANCE NEEDED is the de nition of ‘substantially all’? Although the new requirements may It’s di cult. Our members are already not be particularly expensive, the talking with employers, looking at their challenge, experts say, lies in inter- packages and saying, ‘This is what you preting the law in the absence of have now, and this is what we think you clear guidance. The legislation re- are going to need to comply with the quires regulators to publish nal rules law.’ I think many decisions are going to within 12 months of its adoption. But be made before we have clari cation.” employers can’t wait until October to At the heart of the matter is the quesdesign their programs. tion of what constitutes parity. Parity Consequently, they’re working to un- doesn’t require sponsors to create identi24 MARCH 2009 Edward Jones, PhD, senior vice president of ValueOptions’ commercial division. ValueOptions is an independent behavioral healthcare company. “You have 80 million employees who are working for employers who are self-insured who have been exempt from state mandates.” The ERISA Industry Committee, which represents self-insured organizations, opposed the legislation, arguing that it erodes employer exibility and could threaten other bene ts. Some employers might be forced to raise copays or premiums for both mental-health and core medical bene ts to comply, “because at the end of the day the numbers have to add up somehow,” says Rohan Beesla, who handles health policy for the organization. Experts such as Linda Weaver, a principal with Mercer’s Health and Bene ts Behavioral Health Specialty Group, generally expect compliance will increase overall health bene t costs by less than 2%. That said, increases will vary dramatically, depending on a number of factors, such as the existing disparity between bene ts. Organizations that experience cost increases of more than 2% in the rst year—and more than 1% in subsequent years—can apply for an exemption. But taking advantage of that exemption could be an administrative headache, says Amy Bergner, a principal with Mercer’s Washington Resource Group, noting that it is not clear whether exempt organizations would ultimately have to comply. derstand legislative language that calls for mental health bene ts to be “no more restrictive than the predominant nancial requirements applied to substantially all medical and surgical bene ts covered by the plan.” EXECUTIVE VIEW The Mental Health Parity and Addiction Equity Act requires plans that offer mental health coverage to provide the same financial and treatment coverage that they offer for physical illnesses. Parity began in 1996 when federal government passed legislation requiring parity coverage for annual and lifetime dollar limits. It continued when the FEHB Program adopted parity requirements. Some employers might be forced to change all copays to achieve compliance. cal bene t structures, says ValueOptions’ Jones. “There is exibility as to how you choose to make the bene t parity compliant. It isn’t a simple answer.” For example, it’s not clear whether a sponsor could obtain parity by offering a medical plan that requires a deductible but o ers free o ce visits with a mental health bene t that does not charge a deductible but includes copays. Whether or not those bene ts are on par depends on how the numbers shake out, Jones says. SUBSTANCE ABUSE Stockton, Calif.-based Delta Health Systems is a TPA, serving about 75 plan sponsors. A one-size- ts-all plan for compliance won’t work, says Thomas Partlow, president, because “how they view their plan bene ts is completely di erent.” As a result, Delta is approaching each of its clients with two or three options. Obtaining parity for substance abuse may be particularly challenging, Weaver says. There has often been greater disparity between medical-bene ts coverage and substance-abuse coverage than between medical and mental-health bene ts. Seven percent of employers responding to a 2007 Mercer/Marsh survey reported higher cost sharing for substance-abuse treatment relative to cost sharing for mental-health treatment. While it may take a few years for plan sponsors to navigate the new requirements, and they may incur some additional costs in doing so, employers and employees stand to bene t. “There is an argument that plenty of these mental health issues are a ecting absenteeism, presenteeism and productivity and physical health,” Partlow says. “That is a very real potential savings.” MHE FOR MORE INSIGHT See more Health Management on managedhealthcareexecutive.com http://www.managedhealthcareexecutive.com
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