Short-Term Analysis to Support Mental Health and Substance Use Disorder Parity Implementation. Consultations with Industry Representatives


RAND interviewed several industry representatives, and in this section we summarize their perceptions of the parity legislation and regulations, including their concerns. Industry representatives reported that implementation of parity regulations may have challenging and far-reaching business consequences for the MBHO industry. Some sectors of the industry report that they are facing much more complicated implementation issues than others. The implementation of parity regulations is seen as fairly straightforward for organizations that are integrated medical and behavioral health managed care plans.

Our interviews identified special issues that may confront the MBHO carve-out business. Comparisons with general medical plan features can become very complex, because hundreds of different general medical plans can be involved. The MBHO can employ a strategy that makes comparisons and adjustments on a plan-by-plan basis, which imposes greater complexity of management (and increases administrative costs). A key concern is that if the MBHO adopts a more centralized management strategy, carve-out clients (the clients in this case are the self-insured employer or the major medical plan) may find their behavioral health benefit management misaligned with its corresponding major medical plan. Because the behavioral health carve-out is often not the “at-risk” plan, but instead is a provider of administrative services only, it can make recommendations, but the client ultimately determines key features of NQTLs. Some MBHOs, through an era of mergers and acquisitions, have become very large organizations with a multiple and diverse book of business; consequently, according to some industry representatives, implementation of the IFR is a complex undertaking, which begins with investment of considerable time and resources to collect the information needed to evaluate compliance, let alone respond. In addition to these general observations, these industry representatives offered the following specific observations on types of NQTLs.

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