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MHAMD Perspectives

CMS Issues Letter to States Clarifying Parity Requirements for Medicaid

In early January, CMS issued a letter to State Medicaid Directors confirming that all Medicaid MCOs must be compliant with federal parity law. The letter also directed Medicaid Directors to ensure that the new Medicaid expansion population and the Children’s Health Insurance Plan recipients would also receive parity compliant Medicaid plans no matter the delivery model. Also, and most interestingly, the letter urges states to comply with parity for all Medicaid recipients, no matter the delivery model. This is is especially important in states like Maryland that use an Administrative Services Organization to deliver mental health and substance use disorder treatment. CMS has promised to issue future regulations/guidance to enforce this requirement.

Other recently released regulations provide more Medicaid clarification regarding the Medicaid benchmark plans applicable to the new expansion population. The new regulations also include a new provision allowing states to increase cost-sharing for participants for non-preferred drugs and non-emergency use of Emergency Departments. The entire 473 page rule can be found here.

CMS also just released a set of FAQ addressing various Medicaid questions. Of note is the answer to the question about the Basic Health Plan. HHS has decided to delay implementation of this program until at the earliest 2015. Questions also address reimbursement rates and eligibility issues. To read all the FAQs.

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