by Patrick J. Kennedy
Today, I am sharing the below letter with the leadership of all major insurance companies and CMS urging them to take action on implementing the recommendations outlined in the Surgeon General’s Report on Alcohol, Drugs and Health, which was released last week.
We have waited far too long for insurers to take action, and too many lives have been lost as a result. I am calling on America’s health insurance companies and CMS to share their action plans on January 24th in Washington, DC, as part of my event, “The New Frontier of Mental Health and Addiction.” This is insurers’ moment to demonstrate commitment to putting their customers’ health needs first, and I challenge them to seize this opportunity to solve one of the nation’s most critical public health issues.
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To the nation’s leading insurance providers,
In the introduction to the first-ever Surgeon General’s Report on Alcohol, Drugs, and Health, released in November, the Surgeon General explains that the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA) and the Affordable Care Act incentivize health care organizations to integrate substance use disorder treatment with general health care. The report goes on to state that “many questions remain, but those questions are no longer whether but how this much-needed integration will occur.” As the nation’s leading insurance providers, you have a tremendous opportunity — and obligation — before you to demonstrate your commitment to better health for all of the people you serve.
Below are five things that you can do immediately to ensure the objectives of this report, which include saving many lives from accidental overdose, are realized.
1 Eliminate the onerous medical management practices responsible for inadequate, ineffective treatment of addiction. MHPAEA requires that the financial requirements and treatment limitations imposed by most health plans and insurers for substance use disorders be no more restrictive than the financial requirements and treatment limitations they impose for medical and surgical conditions. Put simply, it’s the law. Don’t wait for your customers to file a complaint after their rights have been violated. Do the right thing, and proactively ensure that your plans are in compliance with the law. This includes, but is not limited to, eliminating managed care restrictions on reimbursement for substance use disorder treatment in inpatient settings, such as limitations on length of residential rehabilitation stays.
2 Immediately ensure that all plans cover and reimburse for well-supported medication assisted treatment (MAT) including buprenorphine, buprenorphine-naloxone, buprenorphine-hydrochloride, methadone, naltrexone, acamprosate, and disulfiram at rates equal to coverage for medications used to treat other forms of chronic illness. These medications, especially when combined with counseling and other behavior therapies, have been repeatedly proven to be highly effective treatment options for individuals with alcohol and substance use disorders. Studies continue to demonstrate the efficacy of MAT at reducing illicit drug use and overdose deaths, improving retention in treatment, and reducing HIV transmission. This includes, but is not limited to, the immediate elimination of ‘fail first’ programs, lifetime medication limits, duration limits, step therapy requirements and preauthorization. I applaud Cigna for its decision to eliminate preauthorization, and urge all insurers to follow suit.
3 Incentivize greater coordination of care. The Surgeon General’s report clearly states: “Effective integration of prevention, treatment and recovery services across health care systems is key to addressing substance misuse and its consequences and it represents the most promising way to improve access to and quality of treatment.” Although 45 percent of patients seeking treatment for substance use disorders have a co-occurring mental disorder, most addiction treatment programs are not part of, or even affiliated with, mental or physical health care organizations. Similarly, most general health care organizations — even teaching hospitals — do not provide screening, diagnosis, or treatment for substance use disorders. This separation of substance use disorder treatment from the rest of health care contributes to the lack of understanding of the medical nature of these illnesses and slow adoption of evidence-based treatments. By incentivizing more coordinated care, you have an opportunity to decrease overall costs and increase positive health outcomes.
4 Adequately disclose processes for ensuring parity compliance. When a provider is certain that a service is covered by a health plan, they are more likely to receive training and offer an innovative and effective new treatment. If they are not sure, they may choose not to receive training because they may not receive reimbursement for the service. Insurers should issue descriptions of the process used to develop or select the medical necessity criteria for mental health and substance use benefits along with the process used to develop the medical necessity criteria for medical and surgical benefits; and identify all non-quantitative treatment limitations (NQTLs) that are applied to mental health and substance use disorder benefits and all NQTLs that are applied to medical and surgical benefits.
5 Promote screening and work with communities to implement prevention interventions. Evidence-based prevention interventions, carried out before the need for treatment, are critical because they can delay early use and stop the progression from use to problematic use or substance use disorder, all of which are associated with costly individual, social and public health consequences. Prevention can markedly reduce the burden of disease and related costs, and there is strong scientific evidence supporting the effectiveness of prevention programs and policies. Insurance companies must ensure that providers understand the research-based recommendations for prescribing opioids, and do your part to hold them accountable. Aetna sends a letter to doctors prescribing high levels of opiates to patients, and Anthem requires patients who “doctor shop” to receive prescriptions at only one pharmacy, so that pharmacists will notice multiple prescriptions. Upfront investments and reimbursements for evidence-based prevention interventions will reduce both direct and indirect costs related to crime, health and lost productivity.
I invite you to present your action plans at an event I am holding on Tuesday, January 24, 2017 from 11am-1pm in The Kennedy Caucus Room in Washington, D.C. The gathering, “The New Frontier for Mental Health and Addiction,” will provide a bold plan for all members of Congress, regardless of party or committee, to take action on parity enforcement and achieve true equality for the millions of Americans living with the disease of addiction. I urge you to be part of this event, and be part of the solution desperately needed by millions of our fellow citizens.
By taking these steps to comply with the law and achieve the true promise of parity, you can play a pivotal role in solving one of the nation’s most pressing public health crises.
Sincerely,
Patrick J. Kennedy
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About the author: After his 16 year career in Congress serving Rhode Island’s First District, Kennedy is venturing into a new chapter in his life. Kennedy is now working diligently
