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Rebecca Farley

Director, Policy & Advocacy, National Council for Behavioral Health

National Council Releases Template Parity Comments; Submission Deadline is June 9

June 4, 2015 | Parity | Comments
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The National Council has finalized our comments in response to the recently released Medicaid parity proposed rule. Our comments commend the Centers for Medicare and Medicaid Services (CMS) for safeguarding beneficiaries’ access to mental health and addiction care under a variety of delivery system arrangements and for encouraging states to apply parity requirements for all Medicaid enrollees, even those whose coverage isn’t subject to the parity law.

We also offer suggestions for improvement, including by providing more examples of non-quantitative treatment limitations, more clearly articulating how long term care services are defined and ensuring this definition does not absolve states of the responsibility of covering a comprehensive continuum of mental health and addiction care, and providing more detail on how intermediate services (such as residential treatment) should be addressed.

The National Council is offering a template version of our comments to assist any members interested in submitting their own comments to the proposed rule. The deadline for submission of comments is June 9, 2015. Comments may be submitted electronically at or via mail according to these instructions. CMS will review all comments and issue a revised, final version of the regulation at an unspecified future date.