Letter ·

NAMD Comments on Draft Templates for Documenting Compliance with Mental Health Parity Requirements

CMS recently issued a set of templates and instructional guides to document compliance with mental health and substance use parity requirements.

In September 2024, CMS issued a set of templates and instructional guides to document compliance with mental health and substance use parity requirements. Parity regulations prohibit health plans, including Medicaid managed care organizations, from applying more restrictive financial requirements or treatment limitations to mental health and substance use benefits than they apply to medical and surgical benefits.

In our comments, NAMD strongly recommends that CMS make use of these templates optional. While some Medicaid agencies report that the templates would be helpful, other agencies have already invested substantial resources in developing high-performing compliance processes, often in partnership with external experts. If CMS does finalize mandatory use of these templates, they should give states and plans substantial time (18 – 24 months) for implementation. This extended implementation deadline would give Medicaid agencies time to train managed care plans on correct use of the templates and ensure data quality. Read our full comments here.

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