ASAM Joins Letter Urging Finalization of 2023 Proposed Parity Regulations

ASAM joined a letter signed by 40 organizations requesting the Departments of Health and Human Services, Labor, and Treasury finalize the 2023 proposed parity regulations. In the letter, the coalition commended the Departments for proposing comprehensive standards to root out ongoing discriminatory insurance practices and those that impose a greater burden on access to substance use disorder and mental health care. In particular, the coalition commended the proposals' improved definitions, more comprehensive focus on network composition and the related factors that affect access to care, establishment two new tests to measure compliance with non-quantitative treatment limitations (NQTLs), and requirement of analysis and reporting of outcome data for NQTLs, including construing disparate outcome data for network composition as dispositive evidence of a Parity Act violation. Further, to close existing loopholes in the law, the coalition urged the Departments to rescind its proposal to embed two exceptions in the NQTL violation tests (application of generally recognized independent professional medical or clinical standards and standards designed to detect or prevent and prove fraud, waste and abuse and instead to retain the regulatory status quo in which both factors are appropriately considered in relevant NQTL analyses). 

Read the letter here.