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National Parity Discussion

National Parity Discussion. National Behavioral Consortium September 10, 2009 Pamela Greenberg, MPP President & CEO, ABHW Henry Harbin, MD Consultant. REGULATIONS. Departments of Labor, Health and Human Services and Treasury to Issue Regulations 1 Year After the Date of Enactment

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National Parity Discussion

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  1. National Parity Discussion National Behavioral Consortium September 10, 2009 Pamela Greenberg, MPP President & CEO, ABHW Henry Harbin, MD Consultant

  2. REGULATIONS • Departments of Labor, Health and Human Services and Treasury to Issue Regulations 1 Year After the Date of Enactment • RFI released April 28th • Comments were due May 28th • Agencies Received 404 Comment Letters • Interim Final Regulation

  3. Areas That Need Clarification • Are Separate but Equal Deductibles Permitted • Define No More Restrictive than the Predominant Financial/Treatment Limitations Applied to Substantially All Medical and Surgical Benefits • Which State Laws are Preempted • Does the Law Apply to EAPs

  4. Additional Regulatory Comments • Does Parity Apply to: • Management of the Benefit • Fee Schedules • Network Requirements • Are Plans Required to Cover all Evidence Based Treatments/Scope of Services • Can the Plan exclude Certain Types of Providers

  5. National Health Care Reform National Behavioral Consortium September 10, 2009 Pamela Greenberg, MPP President & CEO

  6. Congressional Committees Involved • Senate • Health, Education, Labor & Pensions • Finance • House • Education & Labor • Energy & Commerce • Ways & Means

  7. Behavioral Health Involvement • Whole Health Campaign • SAMHSA • Whole Health Coalition

  8. Status of Legislation • Senate • Affordable Health Choice Act • Finance Committee Policy Options • House Tri-Committee • America’s Affordable Health Choices Act of 2009 (HR 3200)

  9. Some Key General Areas of Interest • Public Option • Employer Requirements • Expansion of Public Programs • Financing • Guaranteed Issue

  10. Some Key Behavioral Health Areas of Interest • Basic Benefits Package/Parity • Prevention & Wellness • SAMHSA • Treatment of Pre-existing Conditions • Adequacy of Provider Networks • Workforce Issues • Medicare – 190 Day Limit

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