20 Steps You Can Take to Be Ready for It
By Joel E. Miller
AMHCA Executive Director & CEO
With the open-enrollment period under the ACA rapidly approaching, mental health counselors should take steps now to learn about the law’s provisions, about how to can take advantage of the opportunities it presents for private practitioners, and about how to help the uninsured understand the ACA’s benefits.
On page 13, we highlighted 10 ways clinical mental health counselors can get their practices ready for healthcare reform and work with other professionals to expand their practices.
Here, we recommend 20 key actions to promote the healthcare reform law overall to facilitate a successful implementation so that it addresses the needs of consumers with mental health conditions.
1. Inform policymakers and decision-makers that if the ACA is implemented properly, more than 13 million uninsured people with behavioral health conditions are now eligible for coverage under the state health insurance exchanges and the new Medicaid expansion programs. These consumers will have a robust package of benefits—including mental health and substance use services—and their mental health benefits will be at parity with medical and surgical benefits.
2. Participate in special task forces and work groups on healthcare reform that have been formed and organized in your locale and state. You can make a difference to your community as well as generate referrals by helping these groups conduct outreach and enrollment initiatives to reach people who are eligible to enroll in the ACA coverage expansions.
- Participate in Outreach, Eligibility, and Enrollment Initiatives
3. Work with other counselors to ensure that health coverage is easily accessible for those eligible to receive it through insurance expansions. This includes knowing whether the new “Navigator” programs are sufficiently funded and staffed to facilitate the enrollment process for individuals for whom the process may be burdensome as well as those transferring from Medicaid enrollment to the insurance marketplaces [Exchanges].
4. Work closely with other stakeholders to ensure that states conduct strong outreach and education activities that are targeted to the public, eligible employers, behavioral health consumers, and service providers to ensure sufficient access to coverage and benefits.
5. Ensure that governing boards and other advisory bodies tasked with developing and administering the coverage expansions (Medicaid and State Exchanges/Marketplaces) include individuals with expertise regarding the unique needs of individuals with behavioral health disorders.
6. To prevent discontinuity of care, advocate for the enrollment needs of individuals moving from institutions and varying transitions of care, such as Institutions for Mental Diseases (IMDs) or prisons to community-based settings.
7. Engage with the State Health Insurance Marketplaces and Medicaid Expansion Programs to determine how best to address enrollment for individuals whose income levels fluctuate between eligibility for Medicaid and insurance marketplaces. Your participation in this area can help ensure that these individuals have consistent access to behavioral healthcare services.
8. As states design and construct their health information exchanges and their enrollment websites, CMHCs couldencourage your colleagues and all stakeholders to think of these pieces as an integrated eligibility and enrollment system that includes Medicaid and the Children’s Health Insurance Program (CHIP), as well as the insurance exchanges.
9. Promote approaches for addressing selection-related incentives, such as carving out all or part of behavioral health benefits, providing reinsurance for some behavioral healthcare costs.
- Make the ACA’s Essential Health Benefits Robust
10. Make recommendations to expand benefit requirements if the Essential Health Benefit Package is not sufficient to meet the behavioral health needs of state residents.
11. Promote an overall benefit to include a universal definition of medical necessity that includes rehabilitation, habilitation, prevention, recovery programs, and long-term-care services to ensure an appropriate continuum of services in the benchmark plans offered by health plans in the health insurance exchanges.
12. Demand that the definition of medical necessity balance the need for consistency with the need to apply the medical necessity definition to each individual, given the totality (behavioral and medical) of that person’s health condition.
13. Encourage your state to coordinate planning the insurance exchange and Medicaid expansion behavioral health benefit so that they are consistent with one another and with traditional Medicaid. Consistency in benefits offered leads to more dependable benefits for persons in treatment.
14. Ensure that decision-makers remain cognizant of behavioral health concerns throughout the entire process, i.e., both during insurance exchange establishment and Medicaid.
15. Identify gaps by first mapping out which populations will be covered by various health-insurance coverage options available under the changing healthcare landscape. The availability of new evidence-based approaches and funding will require large purchasers to rethink what services they purchase as well as how those services are purchased. Although access to Medicaid and insurance exchanges will increase over the next few years, gaps in coverage will remain for specific populations and services. Purchasers and payers will need to determine what specific behavioral health services they should cover in addition to what is being covered by health insurers and other payers.
- Ensure Mental Health Parity
16. Work closely with state insurance divisions. Promote education of, and compliance with, parity requirements by: monitoring results, facilitating handling of consumer complaints; enhancing transparency and accountability; and expanding needed consumer protections.
17. Use ongoing discussions with health plans and healthcare purchasers to develop user-friendly information on the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA).
18. Create special websites for consumers to offer information about the implementation of mental health parity, encouraging individuals and families to share their personal experiences—positive and negative—with parity implementation.
19. Inform stakeholders of the key parity provisions of the MHPAEA legislation and their linkage to 2014 coverage expansions.
20. Assess health plan performance related to access, quality, coverage, and costs. Examine the breadth of diagnoses covered by health plans, and mount a campaign to educate consumers about their insurance benefits.
For more information about how to help uninsured consumers understand the ACA and enroll, see the “Healthcare Reform” section of the Legislative Update article.