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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 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 • RFI released April 28th • Comments were due May 28th • Agencies Received 404 Comment Letters • Interim Final Regulation
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
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
National Health Care Reform National Behavioral Consortium September 10, 2009 Pamela Greenberg, MPP President & CEO
Congressional Committees Involved • Senate • Health, Education, Labor & Pensions • Finance • House • Education & Labor • Energy & Commerce • Ways & Means
Behavioral Health Involvement • Whole Health Campaign • SAMHSA • Whole Health Coalition
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)
Some Key General Areas of Interest • Public Option • Employer Requirements • Expansion of Public Programs • Financing • Guaranteed Issue
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