Mental Health & Corporate "Wellth"   The high cost of general health care has encouraged greater analyses of chronic and persistent conditions.  It is now evident that one cannot successfully (and cost effectively) treat illnesses like hypertension, diabetes, asthma, congestive heart failure, and other conditions without dealing with related (or co-morbid) stress and depression.  Return on investment (ROI) analyses show CEO’s that improving corporate mental health that is in their own best interest, the interest of their employees, and the interest of their company.  It’s time that this problem is addressed by those who can see the broad picture and understand that mental health means corporate “wellth.”  

February 14, 2013

 Carter Center Debate on Medicaid Expansion

and Access to Mental Health services.

Mental Health Parity

1. Interim Final Ruling

2. IFR Comments (Milliman)

2. IFR Safe Harbor (Milliman)

1. True or False: Health plans must be required to cover mental health benefits, or else they won't.

False.  Although most health plans provide limited mental health coverage, about 75% of the population in the United States has some coverage for inpatient (75.7%) and outpatient (75.6%) mental health services.  While mental health benefits are generally covered, they are not generally covered at parity with medical/surgical benefits.

About 95% of private employer sponsored health plans (both those regulated by the Employee Retirement Income Security Act ("ERISA") and through state laws) include some kind of mental health benefit.  Employees have come to expect that mental health benefits will be covered as part of their health plan, however many plans do not meet even a basic mental health benefit (30 inpatient days, 20 outpatient visits, and drug coverage).

2. True or False: The magnitude of the mental health parity problem has been overstated.  Parity between mental and physical benefits is not needed since people have sufficient mental health benefits now.

False.  While employees expect to have mental health coverage, only 59.3 percent of individuals with private, employer-sponsored health insurance (provided through firms with 10 or more employees) had mental health coverage that at least met a basic "benchmark" for benefit coverage of 30 inpatient days, 20 outpatient visits and prescription drugs. (Mercer Worldwide Survey of Employer-Sponsored Health Plans--See chart below.)  This benchmark level of mental health coverage is typical of many health plans, and shows that mental health coverage is much more limited than medical/surgical coverage, which typically has no day or visit limits.  The chart below shows that 36.4% of individuals had mental health benefits that fell below the benchmark, and 4.3% of individuals did not have mental health benefits at all.

Similarly, a recent 2004 Kaiser Foundation Survey found that, although nearly all covered workers (98%) have mental health benefits (see Exhibit 8.2), limits on visits for outpatient care and the number of days of inpatient care remain a common feature of all plan types.  (Note that this response concerns workers covered by insurance, while question one refers to those persons with inpatient and outpatient mental health benefits in the U.S. population.)

Only 19% of covered workers have coverage for an unlimited number of outpatient mental health visits in 2004, while 81% have limits on coverage. The likelihood of having a limit on the number of outpatient mental health visits is similar across plan types (see Exhibit 9.7).

Most plans limit the number of inpatient mental health days covered. Overall, only 21% of covered workers have coverage for unlimited inpatient mental health days. Approximately 59% of covered workers face an inpatient limit of 30 or fewer days (see Exhibit 9.8).

3.  True or False: States have already addressed the mental health parity issue so there is no longer a need for a federal mental health parity law.

False.  A large number of employers that provide private health insurance coverage are self-insured, which means that the employer rather than a regulated insurance company stands behind the guarantee of benefits. Self-insured benefits are regulated by a federal law, the Employee Retirement Income Security Act (ERISA).  State laws, including mental health parity and mandated benefits laws, do not apply to self-insured coverage.  In order to provide mental health parity for all, a federal law is needed.

Approximately 52.0% of employees are covered under self-insured ERISA plans for a total of 43.7 million employees.  The following chart shows ERISA plan membership by size of employer group.Assuming two family members per employee, the total number of persons not directly protected by state mental health parity laws, because these laws are preempted by ERISA, is about 87.4 million lives.  For your convenience I am attaching my letter to you, dated June 14, 2004, which is useful for purposes of this response in that it breaks down by state the number of lives covered under ERISA-regulated health plans.

In addition, while many states have enacted mental health parity laws, many other states have not or have enacted very limited or inadequate laws.  The large states of Florida, New York, Ohio, and Michigan, and other states--Alaska, Idaho, North Dakota, Wisconsin, Wyoming, and the District of Columbia have yet to enact parity; and do not look to do so in the near future.  This means that in these states more than 19.9 million workers and more than 39.8 million plan members under any type of employer-based health plan (whether regulated by ERISA or by state law) lack any protection through parity laws.  Other states, including for example Arkansas and Georgia, have laws of limited application, so that few workers benefit from them.

READ FULL ARTICLE:

2005 MH parity-A Review of the Problem (REB).doc