The Insurance Commissioner is holding a very important hearing on how the mental health parity law has failed to be implemented by insurers over the past four years.
This is our BEST CHANCE to request OIC to write rules that will require insurance companies to give clinicians the right to determine the frequency and length of services based on the patients’ individual needs, not discriminate against successful treatments, and put medical necessity determination back in the hands of clinicians.
The more families and providers attend and testify, the better the chances that our message will be heard. PLEASE PLAN TO ATTEND.
When: 10/22/13 10 am-12 pm (You can arrive up to 30 min early to sign up to testify).
Where: JLOB Hearing Room A, Olympia (You can arrive up to 30 min early to sign up to testify).
Below are some of the issues that will be discussed at the hearing. We are asking you to come prepared with testimony that describes your experience with exclusions of key therapies to treat autism and developmental disabilities or exclude Autism/DD services altogether. Ask the OIC for a CLEAR STATEMENT THAT SUCH EXCLUSIONS ARE DISCRIMINATION against those with autism and developmental disabilities. Please prepare and practice a 2-3 minute testimony. If many people show up, you may only be able to comment that you support the previous testimony.
Thank you for your consideration and for standing together with us for change.
Arzu Forough
Washington Autism Alliance & Advocacy
Consumer Messages for the Hearing
1) Make the general insurance market rules the same or similar as those for EHB
a. Problem – Great EHB rules but those rules are not applicable to general insurance coverage (large market insured)
2) End discrimination in coverage for developmental disabilities/autism
a. Problem - Many plans have exclusions of the key therapies to treat autism and developmental disabilities or exclude developmental disability services altogether. Need a clear statement from the OIC that such exclusions are discrimination.
3) Establish Independent Review Organization (IRO) registry via rulemaking – this is a mental health issue.
a. Problem – many enrollees win at the IRO only to have to appeal all over again at a later time, or have the insurer deny a different insured on same basis.
b. Making the IRO decisions public in redacted format, online in a way that can be used by other enrollees will promote consistency of IRO decisions and assist the Insurance Commissioner to identify systemic issues appearing in IROs.
4) Rulemaking on Medical Necessity
a. Problem – many insurers are imposing visit limits within their evaluation of medical necessity. They use hidden clinical criteria (Milliman, for example) for limiting such coverage. Those criteria are applied without consideration of individual need or the local standard of care.
b. Need rules which confirm medical necessity is an individualized determination and cannot be based solely on the presence or absence of RCT studies. Medical necessity must include an evaluation of the individual’s medical history and whether other therapies or treatments have been demonstrated to be ineffective.
5) Rules must make clear that diagnostic testing is covered.
a. Problem – many insurers exclude diagnostic testing from “mental health” coverage, or place limits on the amount of mental health coverage.