The Mental Health Parity and Addiction Equity Act (Parity Act) provides a framework intended to ease access to long-blocked addiction care by guaranteeing insurance coverage of addiction treatment equal to that provided for other medical conditions.
This study, conducted as a part of the Addiction Solutions Campaign — a consortium of the leading policy, advocacy, education and technical assistance organizations in the addiction field — highlights significant barriers to front-line enforcement for the Parity Act.
Data from this study suggest that the enactment of the Parity Act has not put an end to restrictive coverage and limited reimbursement for substance use treatment in either private insurance or Medicaid. Findings include the following:
- Regulators cannot conduct a complete assessment of parity compliance through form review with even a comprehensive data-gathering template because required information is not available in these documents.
- Consumers cannot ascertain all standards that will determine access to substance use treatment and are not informed of their rights under the Parity Act.
- Neither consumers nor regulators can identify Parity Act violations from plan documents routinely reviewed for plan approval.
- Prescription drug formularies include wide discrepancies in the coverage of, and restrictions on, medications for the treatment of addiction.
For insurance providers and regulatory agencies:
- Plans should be required to submit their internal analyses to demonstrate that coverage is compliant with the Parity Law, including identification of all non-quantitative treatment limitations (NQTLs) and their application.
- As part of review for Parity compliance, Regulatory Agencies should evaluate the scope of prescription drug coverage for mental health and substance use disorder treatment and utilization management requirements.
- Regulatory Agencies should develop model contracts that fully describe substance use and mental health benefits, align standards with Parity Act requirements and inform consumers of their rights under the law.
- Regulatory Agencies should enhance the provider community’s capacity to identify potential Parity Act violations and advocate for plan compliance in network adequacy and rate setting standards.
The research team designed a data gathering template that tracks all plan design features regulated by the Parity Act, including financial requirements, quantitative treatment limitations and non-quantitative treatment limitations (NQTLs), with the exception of network admission standards, reimbursement rates and network adequacy, which were outside the scope of this review. The team then conducted an analysis of publicly available documents for seven health plans offered in the small and large group markets in New York or Maryland. In addition to reviewing the plan documents
provided to regulators, the study team sought to obtain additional information from publicly available documents via simple internet searches (i.e., medical necessity criteria/medical policies).