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Mental Health Parity Analysis

Analysis of mental health parity in Oregon

The Oregon Health Authority conducted an initial mental health parity analysis of the full Oregon Health Plan delivery system in 2018 to meet requirements in 42 Code of Federal Regulations (CFR) §438 Subpart K. Coordinated care organizations (CCOs) and the Oregon Health Plan fee-for-service program participated in the initial analysis, which included an analysis of limitations and an inventory of all mental health, substance use disorder, and medical and surgical benefits offered to OHP members. Results of the initial analysis were reported in August 2018; and in 2019, the CCOs implemented corrective actions in areas lacking parity.

In 2020, OHA tasked Health Services Advisory Group (HSAG), with conducting a follow-up MHP Analysis across the Medicaid delivery system, in part due to each of the CCOs entering into new five-year contracts with the State, to determine if the existing benefits and any non-quantitative treatment limitations remained compliant with the mental health parity regulations.

To meet the requirements of the CMS final rule codified in 42 Code of Federal Regulations (CFR) §438 Subpart K. Oregon's managed care plans must show that limitations (such as day limits, prior authorization requirements or general provider availability) for mental health and substance use disorder services are not substantially different or more limiting than those for medical and surgical services.

Meeting the requirements

To meet the requirements of the CMS final rule codified in 42 Code of Federal Regulations (CFR) §438 Subpart K. Oregon's managed care plans must show that limitations (such as day limits, prior authorization requirements or general provider availability) for mental health and substance use disorder services are not substantially different or more limiting than those for medical and surgical services.

Reports

  
  
Advanced Health CCO Mental Health Parity Analysis - 2020 2/1/2021
AllCare CCO Mental Health Parity Analysis - 20202/1/2021
Cascade Health Alliance CCO Mental Health Parity Analysis - 20202/1/2021
Columbia Pacific CCO Mental Health Parity Analysis - 20202/1/2021
Eastern Oregon CCO Mental Health Parity Analysis - 20202/1/2021
Health Share CCO Mental Health Parity Analysis - 20202/1/2021
InterCommunity Health Network CCO Mental Health Parity Analysis - 20202/1/2021
Jackson Care Connect CCO Mental Health Parity Analysis - 20202/1/2021
PacificSource Columbia Gorge CCO Mental Health Parity Analysis - 20202/1/2021
PacificSource Central Oregon CCO Mental Health Parity Analysis - 20202/1/2021
PacificSource Lane CCO Mental Health Parity Analysis - 20202/1/2021
PacificSource Marion Polk CCO Mental Health Parity Analysis - 20202/1/2021
Trillium CCO Mental Health Parity Analysis - 20202/1/2021
Umpqua Health Alliance CCO Mental Health Parity Analysis - 20202/1/2021
Yamhill CCO Mental Health Parity Analysis - 20202/1/2021
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What is MHP?

Mental health parity, or MHP, means that mental health and substance use disorder services are treated generally the same as, or better than, medical and surgical services.

  • In 2016, CMS Final Rule CMS-2333-F required states and their contracted managed care entities to meet parity in Medicaid, Children's Health Insurance Program and Alternative Benefit Plan benefits.

Learn more

  • The Oregon Mapping Guide includes definitions, links and resources important for parity analysis. It also maps all Oregon Medicaid benefits to the classifications required for parity analysis.
  • The Centers for Medicare & Medicaid Services (CMS) developed MHP resources that include informative presentations, a compliance toolkit, an implementation roadmap, frequently asked questions, and other helpful resources in applying mental health parity requirements.

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