Short-Term Analysis to Support Mental Health and Substance Use Disorder Parity Implementation. Network Management


  • According to the panelists, the number of different kinds of behavioral health providers with hugely different levels and types of training -- which is both more confusing and less regulated than in the general medical arena -- suggests that differential management may be permissible.

    • But panelists noted that there are areas of general medical care where there is similar variability in provider training -- such as in foot care (surgeons and podiatrists), pain management (anesthesia nurses, anesthesiologists, acupuncturists) and physical medicine (physiatrists, physical therapists and occupational therapists).

  • Plans may have network admission criteria that include experience requirements (e.g., 2-3 years of post-degree supervised clinical experience) for certain types of behavioral health providers. These can be justified when training and licensing requirements are highly variable across states and do not consistently require relevant and appropriate supervised clinical experience.

    • Experience requirements should be clinically reasonable given the type of clinical practice the provider engages in, and no more stringent for behavioral health providers than the experience requirements included in licensure for general medical providers.

  • Similar network adequacy metrics should apply to both behavioral provider networks and general medical networks.

    • It would not be equitable, for instance, if there were egregious variations in access rates, wait times, availability of specialists, etc.

    • Differences across geographic regions and urban/rural areas in network adequacy are also expected because of differential availability of providers.

  • Fee standards should be arrived at using the same type of process but the result does not have to be the same (i.e., fees for providers may be under-market for both behavioral health and general medical providers).

    • It would be inequitable to have general medical fees tied to Medicare but not tie behavioral health fees to Medicare. If Medicare-based fee standards are not available for some types of behavioral health providers/services, then parity implies that, whatever market standards are used, behavioral health providers/services are not differentially and more dramatically underpriced relative to their market than general medical providers/services.

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