The National Association for Behavioral Healthcare (NABH) represents the full continuum of behavioral healthcare services, including not-for-profit and for-profit systems that treat children, adolescents, adults, and older adults with mental and substance use disorders. NABH members provide care across inpatient behavioral healthcare hospitals and units, residential treatment facilities, partial hospitalization and intensive outpatient programs, opioid treatment programs, specialty outpatient services, and recovery support services in 49 states and Washington, D.C. We are pleased to submit the following statement for the record.
In its recent lawsuit, the ERISA Industry Committee (ERIC) purports to represent the interests of large (self-funded) employers, although NABH – including its large employer members – surely support the newly enacted regulations that attempt to implement the Mental Health Addiction and Equity Treatment Act of 2008 fully and fairly.
Compounding matters, ERIC’s lawsuit risks harming consumers with fully insured health plans, even though ERIC does not represent their or their employer’s interests.
Most notably, it is striking that, in the second paragraph of its complaint, ERIC states that “All that is required is parity in particular plan terms and their application, not parity in access to MH/SUD benefits, much less provision of particular benefits.”
In this way, ERIC is challenging even the parity comparative analysis intended to promote transparency and compliance. Essentially, ERIC is arguing that parity should exist in name only and need not result in real world access to care or equitable outcomes. This is perverse, and NABH strongly objects to this interpretation.
About NABH The National Association for Behavioral Healthcare (NABH) represents provider systems that treat children, adolescents, adults, and older adults with mental health and substance use disorders in inpatient behavioral healthcare hospitals and units, residential treatment facilities, partial hospitalization and intensive outpatient programs, medication assisted treatment centers, specialty outpatient behavioral healthcare programs, and recovery support services in 49 states and Washington, D.C. The association was founded in 1933.
NABH has sent letters to policymakers in the House and Senate who introduced respective versions of the Opioid Workforce Act of 2018 to expand and improve addiction medicine, addiction psychiatry, or pain management residency positions to address America’s opioid crisis.
CMS proposed rule on inpatient PPS for acute-care hospitals (including section on IPF Quality Reporting Program). See pages 20120-20127 on IPFQR. Also see CMS news release and fact sheet.
