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Parity testimony delivered to HHS and ONDCP

June 11, 2016

This is the written testimony I prepared for the Listening Session on June 10 at the Department of Health and Human Services. If you would like to learn more about the President's Parity Task Force, please go to\parity. If you would like to give testimony yourself, please send it to Special thanks to all who provided examples for use in this testimony. I incorporated every response.

My name is Ron Manderscheid, PhD. I am the Executive Director of the National Association of County Behavioral Health and Developmental Disability Directors and the National Association for Rural Mental Health. I also am the Co-Chair with Paul Samuels of the Coalition for Whole Health, an entity that represents about 165 national and state mental health and substance use policy and advocacy organizations.

A few weeks ago, I provided oral and written testimony on parity at a White House Listening Session. The substance of this testimony focused on how we can achieve better implementation of parity to improve the well-being of all Americans. Several specific steps were recommended:

Training: Because parity is an abstract concept, most people have little understanding of it. We need public interest messaging and brochures that explain parity in layman’s terms.
Technical Assistance: State Health Insurance Commissioners and insurance company personnel need to feel comfortable with these complex concepts. Technical assistance sessions and an interactive web capacity are needed.
Monitoring: The Federal Government—specifically HHS—needs to monitor implementation and compliance of private insurance with parity requirements. Monitoring procedures need to be consistent and transparent. The procedure set up by CMS to monitor parity in state Medicaid programs can serve as a good model for this work.

Today, I want to add some concrete examples of parity violations to this earlier testimony. In preparation for today's testimony, I conducted a national canvas of the county behavioral health directors, the members of the College for Behavioral Health Leadership, and about 6,000 other persons with an affiliation to behavioral healthcare.

The types of violations reported to me include:

Care Denial: In one instance, a mother was forced to raise $154,000 to pay for the care of one son, and $24,000 to pay for the care of a second son, both of whom suffer from very serious mental health and addiction comorbidities, because care was denied by the family’s health insurance company.
Different Lengths and Combinations of Care: Shorter and less intensive care is provided for behavioral health conditions than for medical conditions.
Different Copays and Payment Regimens: Different copays are required for drugs to treat medical and behavioral health conditions, and different payment regimens are required for medical and behavioral health conditions.
Inadequate Care Networks: Care networks for behavioral health require longer wait times, less care access, and offer less qualified providers than those for medical care due to very low reimbursement rates.
Use of “Fail First” Approaches: Use of "fail first" for behavioral healthcare when similar approaches are not used for medical care.

Growing frustration with these parity violations is leading some provider and consumer groups to consider court action against insurance companies.

Clearly, as outlined earlier, much more needs to be done by HHS and ONDCP to remedy these problems which affect both the mental health and substance use fields.

We are delighted that the president has created a Task Force on Parity, and we thank both of you for your dedication to a successful outcome for this Task Force. 

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