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


  • The panel discussed how behavioral health providers (in particular some types of substance abuse treatment counselors and psychotherapists) do not have consistent training or credentialing standards across subfields, and there is also considerable variation in licensing standards for these types of providers across states. This discussion suggested that it may be clinically appropriate for plans to have additional criteria (such as experience requirements) for inclusion in networks.

  • The panel did not feel qualified to offer specific opinions on data sources for setting network fees and UCR fees for out-of-network providers, but generally agreed with the principle that use of market data to set fees should be similar across behavioral health and other medical providers (for example, basing fees on a multiple of Medicare fees).

  • The relationship between fees and network adequacy is an important parity consideration.

    • Network adequacy is routinely reported by plans using indicators such as access, waiting times, availability of certain specialty care (and others). The panel recognized that network adequacy is influenced by availability (e.g., rural areas may have limited availability of certain kinds of specialists).

    • If fees offered for behavioral health providers are so low that network adequacy is poor, relative to medical network adequacy, then this would raise an issue of parity.

  • There was considerable discussion about exclusion of primary care providers in behavioral health networks, because primary care providers often treat behavioral health conditions, and there is growing evidence of effectiveness of some primary care based treatment models. ASPE staff noted that they recognized the importance of this issue, but suggested that the complexity of reimbursement issues were beyond the scope of the panel’s charge.

The Expert Panel agreed on the following examples for regulators use in providing additional guidance to the field -- but also raised a number of questions.

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