COMMENT on proposed Essential Health Benefits (EHB) rule
Deadline: December 26, 2012 before midnight ET
On November 26, the U.S. Department of Health and Human Services (HHS) published a proposed rule for Essential Health Benefits (EHB)—the ten categories of care, including mental health and substance use disorder services—that will be required in individual and small group health plans and plans offered through health insurance “Exchanges.”
The proposed rule reinforces that parity of mental health and substance use disorder treatment is required. The rule also proposes a slightly stronger requirement for coverage of medications than a previous publication. However, NAMI believes stronger language is needed to protect children and adults who live with mental illness in multiple areas of the rule. To view NAMI’s recommendations, read NAMI’s EHB rule comments (scroll down to Testimony, Comments and Advocacy Letters).
Federal regulators need to hear from you. Numbers count: join NAMI in submitting comments about the proposed Essential Health Benefits (EHB) rule by Wed., Dec. 26 before midnight ET. Please distribute to your members; more comments make a stronger impact.
How to submit comments
1. Go to http://www.regulations.gov/#!docketDetail;D=CMS-2012-0142
2. Click Comment Now button
3. Enter your name and other information
4. Attach NAMI’s EHB Rule comments under Upload Files
Copy and paste our mini-comments (see below) into the Type Comment box
5. Click Submit
Mini-Comments (<2000 characters) to copy-and-paste into the online form:
As a member of NAMI, I am pleased to submit the following comments on the proposed Essential Health Benefits rule:
§ 155.115 (a)(2) Mental health parity
Define a federal process for ensuring that plans comply with parity and require plans to release detailed information about coverage of mental health and substance use services to allow public transparency on parity.
§ 156.110 © Benchmark plans that do not meet EHB requirements
Define a process for adding to benchmark plans when benefits do not meet rule requirements at no extra cost to states.
§ 156.110 (e) Balance among categories of benefits
Adopt a standard for balanced benefits among the ten EHB categories and a federal process for ensuring that plans comply.
§ 156.110 (f) Habilitative services
Define habilitative services for benchmark plans, including the types of covered benefits, to make sure that that people whose skills or functioning are affected by mental illness are covered for needed services.
§ 156.115 (b) Substituting benefits within categories
Adopt standards for substituting benefits that make sure that people living with mental illness are not left with inadequate or no coverage for the types of care they need.
§ 156.120 Prescription drug benefits
Require plans to cover “all or substantially all” antidepressants and antipsychotics and adopt the patient-friendly processes in Medicare Part D for requesting drugs that are not covered.
§ 156.125 Plan benefits may not discriminate
Require plans to report on which benefits they do not cover and adopt a standard for non-discriminatory coverage and a federal process for ensuring that plans comply.
§ 156.130 © Out-of-network cost sharing requirement
Require that cost-sharing for out-of-network specialty mental health services count toward the annual limit on cost sharing and deductibles.
§ 155.170 Benefits required by state law
Allow benefits required by state law at any date to qualify as Essential Health Benefits at no extra cost to states.
Please forward to your friends and members. Thank you for your advocacy!
Director of State Policy NAMI
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