The authors submitted this comment letter to the Centers on Medicare and Medicaid Services on December 4, 2023.
The Center for Medicaid and Children’s Health Insurance Program (CHIP) Services recently put forth a request for public comment in light of recent statutory and regulatory updates to the Mental Health Parity and Addiction Equity Act (MHPAEA). Building on recent work to further advance parity for mental health and substance use disorder care, Richard G. Frank and Chloe Zilkha offered comments and suggestions on some of the provisions in the request.
Their comments highlight how assessment and measurement of outcomes can effectively identify health plans where significant MHPAEA compliance problems may exist in a fashion that can reduce the administrative burden associated with the existing approaches to assessment of non-quantitative treatment limitations (NQTLs). The remainder of their comments address barriers to accessing behavioral health care for Medicaid and CHIP beneficiaries as focal points for MHPAEA compliance.
Acknowledgements and disclosures
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