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In a December bulletin, the U.S. Department of Health and Human Services (HHS) proposed to give states wide discretion to set their own essential health benefits (EHB) standard for health plans sold through the new exchanges. However, there are challenges ahead for children's mental health supporters as this does not have a clear-cut, comprehensive federal standard to help guide the process. It is our belief that if left up solely to the states, we could see significant disparities in coverage.
Here are the four key points you need to make in your message to HHS. Cut and paste or create your own message:
Please send comments to EssentialHealthBenefits@cms.hhs.gov
Subject line: Re: Comment on Essential Health Benefits Bulletin
1. Support the Inclusion of a Wide Array of Mental Health Benefits and an Expanded Work Force to Carry Them Out
- We risk going backward if what is required in the mental health component only includes inpatient and outpatient mental health services. The Bulletin must stress the importance of intensive community-based mental health services for children, youth and their families. Since the early 1980's the Children's Mental Health Initiative has been showcasing the value of a systems of care approach in meeting the mental health needs of children and families.
- Essential benefits must include services such as respite care, parent support providers, behavioral aides and therapeutic mentoring. The Essential Health Benefits standard should include broad coverage of home supports and related services. Ultimately, a relatively inexpensive set of home support services, along with robust coverage of rehabilitative and habilitative services, is necessary to be in compliance with both Affordable Care Act (ACA) and Americans with Disabilities (ADA) law. Robust coverage would also prevent countless unnecessary hospitalizations and maximize the functional status, independence, and quality of life of enrollees.
- The estimate is that with the Affordable Care Act an additional 37 million people will receive coverage - and that is a good thing! Expanding coverage to intensive community-based services and supports will require an expanded work force, including respite providers and parent support providers.
2. HHS Should not Allow a "Minimum Standard"
- The Bulletin should not allow state or insurer flexibility to go below a national Essential Health Benefits floor or allow flexibility that will discriminate against individuals with disabilities, functional limitations, or mental health, behavioral health and substance abuse conditions or otherwise undermine efforts to achieve true parity in benefits.
3. Support the "Plus" in the "Plus Ten" Approach
- The Affordable Care Act in its simplest form says that the Secretary must design an Essential Health Benefits package equivalent to a typical employer plan plus ten additional categories. Here is the "plus" part - A fundamental principle in the Affordable Care Act is that by investing in critical services, we will transform health care coverage and reduce long term spending. It would make no sense for the Affordable Care Act to, with regard to the Essential Health Benefits standard, list the critical services and then suggest they be covered only to the minimal extent already covered. It is no coincidence that the "plus ten" categories include critical gap services like preventive and wellness services and it is the Affordable Care Act's intent to invest in these services beyond current minimum norms. It is important to emphasize that the Affordable Care Act calls for a typical employer package "plus ten." Mental health and substance abuse services are included in the ten categories, however the rehabilitative and habilitative services necessary for intensive community-based services do not seem to be in place as they are in State Medicaid plans. For example, mental health rehabilitative and habilitative services are virtually non-existent in typical employer coverage. It would make no sense for the Affordable Care Act to create a requirement to cover a specific service "in the same scope as a typical employer" when that coverage is nearly nonexistent. For the inclusion of a service like intensive home-based servcices, wraparound, respite care or parent support provider to make any sense, each of the categories must be defined "beyond current minimum norms" and not satisfied by alignment with current employer coverage (or lack of coverage).
4. Require a Uniform Set of National Benefits
- The Bulletin suggests that HHS will allow states to benchmark to a "reference plan" that is based on a currently available health plan in the state, modified as needed to meet the Essential Health Benefits requirements found in the Affordable Care Act. Allowing states to create their own variations of the Essential Health Benefits package will undermine the intent of the Affordable Care Act to create a comprehensive and national standard for health insurance coverage. We must make sure there are clear federal minimum Essential Health Benefits requirements and standards to ensure that vulnerable populations can access comprehensive care that consistently meets their needs across states.
Please send comments to EssentialHealthBenefits@cms.hhs.gov through today - so take 10 minutes (the time it takes to stand in line for a coffee or sitting in the drive-through lane picking up lunch). If you can do that today you surely can do this!
Want more details on our full set of considerations for the HHS Bulletin? Read more here.
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