MAAPPN expressed congratulations to the MA Attorney General for the report on June 30th, 2015 identifying the impact of “historically low reimbursement rates” as undermining our states’ health care reform goals including access to behavioral health services and the impact on overall medical expenditures for consumers with behavioral health disorders. In addition, the process of rate determination was taken to task as a possible parity violation.
In a letter to the AG, MAAPPN along with other Mental Health Coalition members stated:
“We are concerned that the historically low reimbursement rates that you reference may in part be the result of a process of determining reimbursement rates for behavioral health services that are qualitatively different than the process used for setting reimbursement rates for medical and surgical services. If this concern is valid, then we speculate that this may represent a violation of state and/or federal mental health parity laws.We understand that your office has some responsibility with regard to enforcing mental health parity laws. We urge you to consider whether to use your investigative powers to determine whether mental health parity laws are being violated with regard to how health plans, and their respective managed behavioral health organizations, are setting reimbursement rates for behavioral health services and to take whatever steps necessary to enforce these laws.Again, we commend you and your Health Care Division for this important report. We believe it is a vital step towards addressing behavioral health services access and understanding that increasing expenditures for behavioral health services is instrumental in containing overall healthcare expenditures. We hope that you will follow up on the spirit of this report with appropriate investigative and enforcement actions, and we would be pleased to provide any assistance that may be helpful to your work on behavioral health issues.
MAAPPN has further suggested to the AG that they hold a “Listening Session ” with the Mental Health Coalition to further identify the our specific concerns about parity violations in rate setting.