Mental Health America local CEO Scott Suckow leaving local organization June 1st
SAN DIEGO, CA (April, 7, 2010) -- Mental Health America of San Diego County (MHASD), San Diego’s oldest non-profit mental health advocacy organization, has announced that Scott Suckow, Chief Executive Officer, will leave the organization effective June 1st of this year. Mr. Suckow has accepted the position of Vice President of Community Partnerships with Mental Health Systems, Inc. and will continue his mental health advocacy work.
Mr. Suckow has served as the CEO since the agency merged with Alpha Behavioral Health Services (AlphaBHS) in January 2007. Prior to the merger Suckow held the position of Executive Director of AlphaBHS.
“As MHASD moves forward towards its goal of making San Diego a mentally healthier community through advocacy and public education, the Board of Directors thanks Scott for his leadership during a time of transition and growth,” stated Richard Conklin, Board President of MHASD. “The Board will start its search for a chief staff person to continue the momentum by implementing our new strategic direction.”
To maintain stability during the search Peggy Beers, the organization’s Vice President of Programs, has been appointed as the Interim CEO. Ms. Beers has been with MHASD for thirteen years and is currently a member of the organization's management team.
Since the merger, MHASD has successfully undergone a strategic board recruitment process, strengthened its internal operations, expanded the operating budget by nearly 200%, and completed an 18-month strategic planning process funded by The California Endowment and The Parker Foundation.
“I feel privileged that I had a chance to work with Mental Health America during this exciting period,” said Suckow. “Additionally, as a family member of someone living with Schizophrenia, I remain committed to continuing to work within the mental health sector in my new role”.
As Vice President of Community Partnerships with Mental Health Systems, Suckow will join the Mental Health System’s leadership team in creating access and breaking down barriers for individuals and families living with behavioral health problems who either cannot afford privately paid services or for whom appropriate services are not otherwise available.
“We are pleased to have someone with Scott’s background joining our organization in the Development Department,” stated Kimberly Bond, President of Mental Health Systems, Inc. “Scott has a long history of involvement in the non-profit community, particularly around improving access and standards of care in the healthcare sector. Over the course of his career, he has raised millions of dollars to fund research, patient education and outreach programs. These skills will support MHS as we respond to meet the needs of those living with behavioral health issues”.
Suckow has held leadership positions throughout the country with some of the nation’s leading voluntary health agencies. In addition to serving locally on numerous boards and commissions, in 2009 he was named one of San Diego Magazine’s “50 People to Watch” and is a 2009 LEAD San Diego graduate. Suckow will hold his current position through MHASD’s annual Healthy Minds Luncheon on May 4th, honoring Rady Children’s Hospital San Diego CEO Kathleen Sellick (www.hml2010.kintera.org).
About Mental Health America of San Diego County:
Mental Health America of San Diego County (MHASD) is the county’s oldest non-profit dedicated to helping ALL people liver mentally healthier lives. As part of a national organization with more than 300 affiliates nationwide, MHA represents a growing movement of Americans who promote mental wellness for the health and well-being of the nation – everyday and in times of crisis. (www.mhasd.org)
About Mental Health Systems, Inc.:
Mental Health Systems, Inc. (MHS) began in 1978 by providing psychiatric day treatment and alcohol recovery services to adults in North San Diego County. Today MHS operates more than 90 community-based mental health and substance abuse rehabilitation programs throughout California and in Utah.
Using best-practices to develop treatment protocols, MHS programs are designed to serve the needs of those individuals with behavioral health problems who either cannot afford privately paid services or for whom appropriate services are not otherwise available. These services are publicly funded and aid the neediest segments of the population. (www.mhsinc.org)
Wednesday, April 7, 2010
Wednesday, March 24, 2010
Mental Health America Hails Enactment of Historic Health Care Bill
Mental Health America today hailed the “Patient Protection and Affordable Care Act” signed by the President. The legislation will greatly expand access to mental health care and addiction treatment—particularly for the 32 million previously uninsured Americans who will gain access as a result.
Treatment for these conditions is recognized as critical to overall health by being included on the list of essential benefits that must be covered in new plans offered to the uninsured.
“This health care reform legislation marks a tremendous step forward in our efforts to improve access to care for individuals with mental health or substance use conditions and in our advocacy for prevention of these conditions” said David Shern, Ph.D., president and CEO of Mental Health America.
The groundbreaking achievement last year with the enactment of the “Mental Health Parity and Addiction Treatment Act” (MHPAEA) firmly established that discriminatory limits on these conditions will no longer be permitted. Mental Health America is pleased to see the health care reform legislation carries this principle forward and extends the MHPAEA requirements beyond current law to health insurance plans offered to small businesses and individuals. These principles are also reflected in the expansion of Medicaid which would require those newly eligible to receive mental health and substance use services at parity with other benefits.
Access to care will also be improved due to insurance market reforms in this new law that will prohibit pre-existing condition exclusions, rescissions of coverage when people most need it, pricing premiums based on health status, and annual and lifetime limits on benefits.
The health care reform law will also establish a new requirement that coverage for dependent children must be available up to age 26 and will provide additional funding for school-based health clinics. Both provisions are critical in light of the fact that mental health conditions often strike during the adolescent and young adult years but most will not receive treatment until many years later, if at all.
Mental Health America places a high priority on prevention, particularly among children and youth, and thus we are please with the new requirements to cover preventive services as well as programs to support community-based prevention activities.
“We also strongly support the provision in this law that will eliminate the donut hole in the Medicare prescription medication coverage as Medicare is a crucial source of support for millions of people with behavioral health conditions,” Dr. Shern said.
Among the many other important new programs and reforms are initiatives to support education and training of additional mental health and addiction treatment providers and to improve coordination of care through a new state option for medical/health homes in Medicaid that includes individuals with serious mental health conditions among the priority populations.
Treatment for these conditions is recognized as critical to overall health by being included on the list of essential benefits that must be covered in new plans offered to the uninsured.
“This health care reform legislation marks a tremendous step forward in our efforts to improve access to care for individuals with mental health or substance use conditions and in our advocacy for prevention of these conditions” said David Shern, Ph.D., president and CEO of Mental Health America.
The groundbreaking achievement last year with the enactment of the “Mental Health Parity and Addiction Treatment Act” (MHPAEA) firmly established that discriminatory limits on these conditions will no longer be permitted. Mental Health America is pleased to see the health care reform legislation carries this principle forward and extends the MHPAEA requirements beyond current law to health insurance plans offered to small businesses and individuals. These principles are also reflected in the expansion of Medicaid which would require those newly eligible to receive mental health and substance use services at parity with other benefits.
Access to care will also be improved due to insurance market reforms in this new law that will prohibit pre-existing condition exclusions, rescissions of coverage when people most need it, pricing premiums based on health status, and annual and lifetime limits on benefits.
The health care reform law will also establish a new requirement that coverage for dependent children must be available up to age 26 and will provide additional funding for school-based health clinics. Both provisions are critical in light of the fact that mental health conditions often strike during the adolescent and young adult years but most will not receive treatment until many years later, if at all.
Mental Health America places a high priority on prevention, particularly among children and youth, and thus we are please with the new requirements to cover preventive services as well as programs to support community-based prevention activities.
“We also strongly support the provision in this law that will eliminate the donut hole in the Medicare prescription medication coverage as Medicare is a crucial source of support for millions of people with behavioral health conditions,” Dr. Shern said.
Among the many other important new programs and reforms are initiatives to support education and training of additional mental health and addiction treatment providers and to improve coordination of care through a new state option for medical/health homes in Medicaid that includes individuals with serious mental health conditions among the priority populations.
Thursday, March 4, 2010
Drug Switching
Forwarded from the Alliance for Patient Access(AfPA): I wanted to bring to your attention two new initiatives underway at AfPA. As you are aware, for several years AfPA has worked to raise awareness amongst physicians, patients and policymakers with respect to the issues surrounding therapeutic substitution or “drug switching”. To that end, AfPA launched yesterday a new educational Internet video to can be used by physicians to caution patients regarding potential risk associated with this practice. To view the video please visit http://www.allianceforpatientaccess.org/protect.php I would encourage you to share this link with patient advocates and others who might be able to put it to good use.
Alliance for Patient Access
www.AllianceforPatientAccess.org
Alliance for Patient Access
www.AllianceforPatientAccess.org
Returning Service Members: Reconnecting With Your Children
Returning Home
If you’re a returning service man or woman who is also a parent, you probably carried a mental picture of how your homecoming would be. It may have included your baby uttering his or her first “Daddy” or “Mama,” your toddler running towards you with outstretched arms, or your older child huddling close and begging to hear about your experiences. Such expectations may lead to disappointment. Because what sometimes happens is an initial display of happiness on the child ’s part followed by sulky, withdrawn or even hostile behavior.
To understand why this happens, you must first realize that even just a few months seem like a lifetime to a child, and children instinctively adjust to new situations. They adjusted to you not being around. Now, they need time to adjust to having you around again.
Your child’s reactions depend on his or her own personality, but there are several things that all returning parents should keep in mind:
• Tell your children how much you missed them and how happy you are to see them again. It may seem like they should know this, but they need to hear it from you.
• Praise them for helping out while you were gone. Children are unsure what to expect from a returning parent. For example, they may fear they will be punished for six months’ of bad behavior. They may also fear you’ll “abandon” them again. Put their minds at rest.
• Remember that change is just as stressful for children as it is for adults – probably more so because they have so little experience coping with it. Sometimes they act out. Remember this before you punish your child.
• Don’t expect the same behavior. He or she has grown physically, emotionally and socially. This is not the same child as when you left.
• Try to avoid power struggles with both your spouse and your children. Take it slowly as you, and they, readjust to your presence.
• Be patient. This period of transition will last several weeks – and it can be awkward. You can ease this by reviewing schoolwork, looking at family photos or asking your children about their activities.
• Allow them to express their feelings. Don’t try to force positive responses.
Preschoolers may act coolly toward you. Acting aggressively or disinterested is their way of showing their hurt and anger at you for leaving. This behavior, though unsettling, usually doesn’t last long. Just tell them how much you missed them, and how you’re looking forward to hearing about the things they did while you were away.
• You can use the same strategies with older children. Express interest in their schoolwork and social activities, and make them feel a part of your life by telling them about your own experiences. Older children usually understand war and deployment a little better than younger ones, but this doesn’t mean they didn’t miss you. Tell them how much you missed them.
Of Special Importance to New Fathers
If you were away for the birth or the first year of your baby’s life, you’ll be coming home to a whole new family. Be aware of the changes:
• You may feel jealous of the attention given to the infant or guilty for being away during the pregnancy and birth. Accept two facts: the separation was inevitable, and the infant’s needs demand attention. Take an active role in caring for the child as soon as possible.
• Baby’s needs come first, and they’re expensive. Be prepared for a much tighter budget.
• Other children may feel lost with all the changes and need help coping. Make sure to spend quality time with your older children.
Of Special Importance to Single Parents
In addition to the joy and stress all parents feel when returning to children after a long absence, single parents may feel particularly anxious about the bond formed by the child and the temporary caregiver. How will it affect their relationship with both of them? Here are some tips:
• Communicate openly and frequently with both the caregiver and the child.
• Involve the caregiver in the transition. Forcing the child to suddenly separate can be just as traumatic as when you left.
• Ask how things were done while you were gone. It will help you plan how to ease your child back into your rules and schedules.
• Ask your child about his or her feelings regarding your “new” relationship and how life at home should be. The changes in caregivers and living arrangements may make children feel as though they have no control over their lives. Assure them that you will be a family again.
For more information, contact Mental Health America of San Diego County at 619-543-0412.
If you’re a returning service man or woman who is also a parent, you probably carried a mental picture of how your homecoming would be. It may have included your baby uttering his or her first “Daddy” or “Mama,” your toddler running towards you with outstretched arms, or your older child huddling close and begging to hear about your experiences. Such expectations may lead to disappointment. Because what sometimes happens is an initial display of happiness on the child ’s part followed by sulky, withdrawn or even hostile behavior.
To understand why this happens, you must first realize that even just a few months seem like a lifetime to a child, and children instinctively adjust to new situations. They adjusted to you not being around. Now, they need time to adjust to having you around again.
Your child’s reactions depend on his or her own personality, but there are several things that all returning parents should keep in mind:
• Tell your children how much you missed them and how happy you are to see them again. It may seem like they should know this, but they need to hear it from you.
• Praise them for helping out while you were gone. Children are unsure what to expect from a returning parent. For example, they may fear they will be punished for six months’ of bad behavior. They may also fear you’ll “abandon” them again. Put their minds at rest.
• Remember that change is just as stressful for children as it is for adults – probably more so because they have so little experience coping with it. Sometimes they act out. Remember this before you punish your child.
• Don’t expect the same behavior. He or she has grown physically, emotionally and socially. This is not the same child as when you left.
• Try to avoid power struggles with both your spouse and your children. Take it slowly as you, and they, readjust to your presence.
• Be patient. This period of transition will last several weeks – and it can be awkward. You can ease this by reviewing schoolwork, looking at family photos or asking your children about their activities.
• Allow them to express their feelings. Don’t try to force positive responses.
Preschoolers may act coolly toward you. Acting aggressively or disinterested is their way of showing their hurt and anger at you for leaving. This behavior, though unsettling, usually doesn’t last long. Just tell them how much you missed them, and how you’re looking forward to hearing about the things they did while you were away.
• You can use the same strategies with older children. Express interest in their schoolwork and social activities, and make them feel a part of your life by telling them about your own experiences. Older children usually understand war and deployment a little better than younger ones, but this doesn’t mean they didn’t miss you. Tell them how much you missed them.
Of Special Importance to New Fathers
If you were away for the birth or the first year of your baby’s life, you’ll be coming home to a whole new family. Be aware of the changes:
• You may feel jealous of the attention given to the infant or guilty for being away during the pregnancy and birth. Accept two facts: the separation was inevitable, and the infant’s needs demand attention. Take an active role in caring for the child as soon as possible.
• Baby’s needs come first, and they’re expensive. Be prepared for a much tighter budget.
• Other children may feel lost with all the changes and need help coping. Make sure to spend quality time with your older children.
Of Special Importance to Single Parents
In addition to the joy and stress all parents feel when returning to children after a long absence, single parents may feel particularly anxious about the bond formed by the child and the temporary caregiver. How will it affect their relationship with both of them? Here are some tips:
• Communicate openly and frequently with both the caregiver and the child.
• Involve the caregiver in the transition. Forcing the child to suddenly separate can be just as traumatic as when you left.
• Ask how things were done while you were gone. It will help you plan how to ease your child back into your rules and schedules.
• Ask your child about his or her feelings regarding your “new” relationship and how life at home should be. The changes in caregivers and living arrangements may make children feel as though they have no control over their lives. Assure them that you will be a family again.
For more information, contact Mental Health America of San Diego County at 619-543-0412.
Tuesday, March 2, 2010
Letter to the Editor: San Diego Union Tribune
Treating the disease of mental illness vs. incarceration
San Diego moves forward to address the escalating number of contacts between individuals with serious mental illnesses and the criminal justice system, as announced in the article by Greg Moran “First person sentenced in program for mentally ill” (March 1). As CEO of Mental Health America of San Diego County, I applaud our criminal justice and behavioral health system’s efforts to break the cycle of worsening mental illness and criminal behavior that begins with the failure of the community mental health system and is accelerated by the inadequacy of treatment in prisons and jails; and to provide effective treatment options instead of the usual criminal sanctions for offenders with mental illnesses. Certainly, not every crime committed by an individual diagnosed with a mental illness is attributable to disability or to the failure of public mental health. But homelessness, unemployment and a lack of access to meaningful treatment services have clearly put many people with mental illnesses at risk of arrest.
Scott Suckow
San Diego
San Diego moves forward to address the escalating number of contacts between individuals with serious mental illnesses and the criminal justice system, as announced in the article by Greg Moran “First person sentenced in program for mentally ill” (March 1). As CEO of Mental Health America of San Diego County, I applaud our criminal justice and behavioral health system’s efforts to break the cycle of worsening mental illness and criminal behavior that begins with the failure of the community mental health system and is accelerated by the inadequacy of treatment in prisons and jails; and to provide effective treatment options instead of the usual criminal sanctions for offenders with mental illnesses. Certainly, not every crime committed by an individual diagnosed with a mental illness is attributable to disability or to the failure of public mental health. But homelessness, unemployment and a lack of access to meaningful treatment services have clearly put many people with mental illnesses at risk of arrest.
Scott Suckow
San Diego
Thursday, February 25, 2010
Making Plans for National Children's Mental Health Awareness Day in San Diego County
Mental Health America of San Diego County will honor Kathleen Sellick for Rady Children’s Hospital San Diego’s integrated pediatric healthcare system that provides the full continuum of care for all children. Ranked among the Nations best children’s hospitals, Rady Children’s provides an array of comprehensive mental health and psychosocial services to children and their families within a full-service pediatric medical facility. Its state-of-the-art, cost-effective clinical programs also are available at outpatient clinics throughout the county.
Making Plans for National Children's Mental Health Awareness Day in San Diego County
As San Diegans gear up to observe Mental Health Month and National Children's Mental Health Awareness Day this May, Mental Health America of San Diego County will honor Kathleen Sellick, President & Chief Executive Officer of Rady Children’s Hospital San Diego at the annual Healthy Minds Luncheon on May 4th at THE US Grant.
In observation of this focus on children’s mental health, Mental Health America asks families to recognize and promote their children's mental health and overall development through increased communication, guidance and emotional support. The theme for Mental Health Month is "Get Connected" to emphasize the important role of social relationships in protecting and improving mental health and building resiliency. Research shows that children who feel warmth and caring from their parents are more likely to be successful in school, less anxious and depressed, and have higher self-esteem than those without.
"Having supportive relationships in our lives is essential for success, happiness and, perhaps most importantly, how we deal with adversity," said Scott Suckow, Chief Executive Officer of Mental Health America of San Diego County. "This is especially true for children. By supporting their mental and emotional needs, parents and other family members can help children think clearly, develop socially, learn new skills, build self-esteem and develop a positive mental outlook."
Here are some easy ways for families to "Get Connected" and build their children's mental health:
* Give unconditional love - Children need to know that your love does not depend on their accomplishments.
* Nurture confidence and self-esteem - Praise and encourage your children. Set realistic goals. Be honest about your mistakes and avoid sarcasm.
* Encourage play - Play time is as important to a child's development as food. Play helps children be creative, develop problem-solving skills and self-control, and learn how to get along with others.
* Enroll children in after-school activities - This is a great way for kids to stay productive, learn something new, gain self-esteem and have something to look forward to during the week. If they are home alone, check in on them after school. Children need to know that even if you're not there physically, you're thinking about them, and interested in how they spend their day.
* Provide a safe and secure environment - Fear can be very real for a child. Try to find out what is frightening him or her. Be loving, patient and reassuring, not critical.
* Give appropriate guidance and discipline - Be firm, but kind and realistic with your expectations. The goal is not to control the child, but to help him or her learn self-control.
* Communicate - Make time each day to listen to your children and talk with them about what is happening in their lives. Share emotions and feelings with your children.
* Get help - If you're concerned about your child's mental or emotional health, consult with teachers, a guidance counselor or another adult who may have information about his or her behavior. If you think there is a problem, seek professional help right away. For more information or referrals to local services, visit us online at www.mhasd.org or contact Mental Health America of San Diego County at 619-543-0412.
Mental Health America founded May is Mental Health Month more than 50 years ago to raise awareness about mental health conditions and the importance of mental health for all. The theme, "Get Connected" is focused on the important role social connectedness plays in maintaining and protecting mental health and wellness. To learn more about how you can connect to the Healthy Minds Luncheon on May 4th, visit www.hml2010.kintera.org or call 619-543-0412 ext. 109.
Making Plans for National Children's Mental Health Awareness Day in San Diego County
As San Diegans gear up to observe Mental Health Month and National Children's Mental Health Awareness Day this May, Mental Health America of San Diego County will honor Kathleen Sellick, President & Chief Executive Officer of Rady Children’s Hospital San Diego at the annual Healthy Minds Luncheon on May 4th at THE US Grant.
In observation of this focus on children’s mental health, Mental Health America asks families to recognize and promote their children's mental health and overall development through increased communication, guidance and emotional support. The theme for Mental Health Month is "Get Connected" to emphasize the important role of social relationships in protecting and improving mental health and building resiliency. Research shows that children who feel warmth and caring from their parents are more likely to be successful in school, less anxious and depressed, and have higher self-esteem than those without.
"Having supportive relationships in our lives is essential for success, happiness and, perhaps most importantly, how we deal with adversity," said Scott Suckow, Chief Executive Officer of Mental Health America of San Diego County. "This is especially true for children. By supporting their mental and emotional needs, parents and other family members can help children think clearly, develop socially, learn new skills, build self-esteem and develop a positive mental outlook."
Here are some easy ways for families to "Get Connected" and build their children's mental health:
* Give unconditional love - Children need to know that your love does not depend on their accomplishments.
* Nurture confidence and self-esteem - Praise and encourage your children. Set realistic goals. Be honest about your mistakes and avoid sarcasm.
* Encourage play - Play time is as important to a child's development as food. Play helps children be creative, develop problem-solving skills and self-control, and learn how to get along with others.
* Enroll children in after-school activities - This is a great way for kids to stay productive, learn something new, gain self-esteem and have something to look forward to during the week. If they are home alone, check in on them after school. Children need to know that even if you're not there physically, you're thinking about them, and interested in how they spend their day.
* Provide a safe and secure environment - Fear can be very real for a child. Try to find out what is frightening him or her. Be loving, patient and reassuring, not critical.
* Give appropriate guidance and discipline - Be firm, but kind and realistic with your expectations. The goal is not to control the child, but to help him or her learn self-control.
* Communicate - Make time each day to listen to your children and talk with them about what is happening in their lives. Share emotions and feelings with your children.
* Get help - If you're concerned about your child's mental or emotional health, consult with teachers, a guidance counselor or another adult who may have information about his or her behavior. If you think there is a problem, seek professional help right away. For more information or referrals to local services, visit us online at www.mhasd.org or contact Mental Health America of San Diego County at 619-543-0412.
Mental Health America founded May is Mental Health Month more than 50 years ago to raise awareness about mental health conditions and the importance of mental health for all. The theme, "Get Connected" is focused on the important role social connectedness plays in maintaining and protecting mental health and wellness. To learn more about how you can connect to the Healthy Minds Luncheon on May 4th, visit www.hml2010.kintera.org or call 619-543-0412 ext. 109.
Friday, January 29, 2010
Mental Health Parity Regulations Released
They’re here! The long anticipated regulations for the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA) were released this morning. In the coming days we will be closely analyzing the interim rule and getting you more information on what we can expect for implementation of MHPAEA. In the meantime, I have attached a fact sheet released by the three Departments issuing the regulations and have highlighted a few further points of interest. I have also included a link to the regulations for your review.
Effective Dates: The Departments of Health and Human Services (HHS), Labor (DOL), and the Treasury released interim rules this morning, and they will be published to the Federal Register on Tuesday, February 2, 2010. The regulations become effective on April 5, 2010 and apply to plan years beginning on or after July 1, 2010. Since the law has been in effect since October 3, 2009, plans should currently be making best faith efforts to comply with the intent of the law.
Opportunity to Comment: The regulations released today are interim final rules, so there will be one more opportunity to comment on them before the final rule is released. (Note: Even if the final rule is not released by July 1, 2010, plans must comply with the interim final rule.) The attached fact sheet contains some of the areas on which the Departments especially want feedback. We will be preparing comments and will share them with the field. The comment period is open immediately and will close on May 3, 2010.
Six Classifications: The regulations clarify that the parity requirements will be applied against “substantially all” medical/surgical benefits in six classification areas. Those six classifications are inpatient/in-network, inpatient/out-of-network, outpatient/in-network, outpatient/out-of-network, emergency department, and prescription drugs. Plans offering mental health and substance use coverage must provide parity in all classification areas where medical/surgical benefits are offered.
Quantitative v. Non-quantitative Treatment Limitations: The regulations distinguish between quantitative and non-quantitative treatment limitations. Quantitative treatment limitations include frequency of treatment, number of visits, and days of coverage, and must be at parity with substantially all medical/surgical benefits. The Departments give separate guidance with examples of parity with medical/surgical benefits for non-quantitative treatment limitations like medical management and utilization management. We will be reviewing the non-quantitative treatment limitations guidance to ensure that the regulations cover all scenarios where treatment can be limited by these types of mechanisms.
Deductibles: Deductibles for mental health and substance use benefits cannot be separate from medical/surgical benefits. Mental health and substance use benefits and medical/surgical benefits must have combined deductibles for financial restrictions and quantitative treatment limitations.
Mental Health as a Non-specialty: Mental health and substance use benefits will not be treated as a specialty, but must be at parity with the predominant medical/surgical non-specialty benefits offered by an insurance plan.
Medicaid Managed Care Organizations (MCOs): While the MHPAEA applies to Medicaid managed care plans, the regulations released today do not. Separate rules for Medicaid MCOs will be released by CMS. We will monitor the release of those rules and update you when they are available.
Non-compliance and Complaints: The Departments are tracking non-compliance and complaints, as well as fielding questions about the regulations. We will send the information on how to determine compliance, file a complaint, and obtain further guidance from the Departments. MHA is also tracking non-compliance and benefit terminations, so please send examples of these to me at ssteverman@mentalhealthamerica.net.
Regulations Link: http://www.federalregister.gov/OFRUpload/OFRData/2010-02167_PI.pdf.
We will have more information and analysis for you in the next several days and weeks. We will also continue to update you on our public education and advocacy campaigns around the implementation of MHPAEA, and look forward to working closely with our affiliates on these initiatives.
Effective Dates: The Departments of Health and Human Services (HHS), Labor (DOL), and the Treasury released interim rules this morning, and they will be published to the Federal Register on Tuesday, February 2, 2010. The regulations become effective on April 5, 2010 and apply to plan years beginning on or after July 1, 2010. Since the law has been in effect since October 3, 2009, plans should currently be making best faith efforts to comply with the intent of the law.
Opportunity to Comment: The regulations released today are interim final rules, so there will be one more opportunity to comment on them before the final rule is released. (Note: Even if the final rule is not released by July 1, 2010, plans must comply with the interim final rule.) The attached fact sheet contains some of the areas on which the Departments especially want feedback. We will be preparing comments and will share them with the field. The comment period is open immediately and will close on May 3, 2010.
Six Classifications: The regulations clarify that the parity requirements will be applied against “substantially all” medical/surgical benefits in six classification areas. Those six classifications are inpatient/in-network, inpatient/out-of-network, outpatient/in-network, outpatient/out-of-network, emergency department, and prescription drugs. Plans offering mental health and substance use coverage must provide parity in all classification areas where medical/surgical benefits are offered.
Quantitative v. Non-quantitative Treatment Limitations: The regulations distinguish between quantitative and non-quantitative treatment limitations. Quantitative treatment limitations include frequency of treatment, number of visits, and days of coverage, and must be at parity with substantially all medical/surgical benefits. The Departments give separate guidance with examples of parity with medical/surgical benefits for non-quantitative treatment limitations like medical management and utilization management. We will be reviewing the non-quantitative treatment limitations guidance to ensure that the regulations cover all scenarios where treatment can be limited by these types of mechanisms.
Deductibles: Deductibles for mental health and substance use benefits cannot be separate from medical/surgical benefits. Mental health and substance use benefits and medical/surgical benefits must have combined deductibles for financial restrictions and quantitative treatment limitations.
Mental Health as a Non-specialty: Mental health and substance use benefits will not be treated as a specialty, but must be at parity with the predominant medical/surgical non-specialty benefits offered by an insurance plan.
Medicaid Managed Care Organizations (MCOs): While the MHPAEA applies to Medicaid managed care plans, the regulations released today do not. Separate rules for Medicaid MCOs will be released by CMS. We will monitor the release of those rules and update you when they are available.
Non-compliance and Complaints: The Departments are tracking non-compliance and complaints, as well as fielding questions about the regulations. We will send the information on how to determine compliance, file a complaint, and obtain further guidance from the Departments. MHA is also tracking non-compliance and benefit terminations, so please send examples of these to me at ssteverman@mentalhealthamerica.net.
Regulations Link: http://www.federalregister.gov/OFRUpload/OFRData/2010-02167_PI.pdf.
We will have more information and analysis for you in the next several days and weeks. We will also continue to update you on our public education and advocacy campaigns around the implementation of MHPAEA, and look forward to working closely with our affiliates on these initiatives.
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