Denials Management, Inc.
HHS Parity Listening Session Comments
Whitney Duhaime, Vice President, Denials Management, Inc.
- The MHPAEA was passed in 2008 and covered large group employers with over 51 employees.
- Americans with Individual plans and employers with 50 or less employees did not receive the benefits and protections of the MHPAEA.
- The Affordable Care Act extended parity protections to small group and individual plans. Under the ACA and its implementing regulations, individual and small group plans must comply with the MHPAEA.
- Predating the ACA, the 2008 Mental Health Parity and Addictions Equity Act (MHPAEA) requires parity in financial and treatment limitations in large group health plans, along with state and local government plans. This provides protections to an estimated 103 million people. The ACA further extended parity protections under MHPAEA to individuals covered by the Medicaid expansion and grandfathered individual and small group market plans. These plans cover 48 million people.
- With all of the uncertainty surrounding the Affordable Care Act, the MHPAEA must be amended to cover individual policies and small group plans for employers with less than 50 employees.
- Federal Employee Health Benefit Plans do not have parity, and we speak with hundreds of families per year who do not understand why their plans are not parity compliant. The MHPAEA should also be amended to include FEHB plans.
- 17 million Americans insured through small group employers (5.3%) will lose Parity benefits in the event of ACA repeal.
- 22 million Americans insured on Federal, State and Local Government plans (6.8%)