AHP Analysis

This Special Report provides a preliminary analysis of the Mental Health Parity and Addiction Equity Act (MHPAEA) Interim Final Rule and regulations. It is written for the benefit of diverse audiences including health plans, payers, state and federal agencies, legislators, mental health and substance use disorder providers, consumer advocates and other stakeholders in the healthcare and health insurance domains. In marked contrast to the highly polarized debate on health care reform currently in process, the MHPAEA was sponsored in a bi-partisan fashion and signed into law by then President George W. Bush. It evolved from more than a decade of earlier state and federal legislation and large scale research, as well as impassioned advocacy, negotiation and compromise between legislators, civil rights and patient advocates, the medical community, the mental health and substance use disorder treatment communities, the recovery community, business, commerce, and health insurance stakeholders. The MHPAEA is a remarkable achievement for all Americans touched by mental health and substance use issues and their many constituencies, as well as an historic example of good policy being enacted through good legislation. The IFR ushers that policy into effect, and this Report, drawing upon the same spirit of cooperation and mutual interest that produced the law, aspires to make the implementation process more informed and effective for all who are involved.

The Report is organized to provide the reader with a detailed summary of the regulations; and an in-depth review of the operational and strategic implications of the Interim Final Rule and regulations from the viewpoint of Plans, Payers and Providers; a review of the challenges and unanswered questions that remain as the MHPAEA is implemented; and the opportunities that are available to stakeholders in the field. The goal is to provide readers with the preliminary analysis necessary to determine their immediate next steps in their respective roles. Collectively, the team of authors that prepared this Report represents a wide range of expertise and experience in all domains of the health care and coverage arena. They have endeavored to provide suggestions that are objective, reliable and timely.