How do the rules impact groups that use third parties to administer mental health and substance abuse benefits?
Many in the industry expected that the federal government would allow one deductible for medical benefits and another for mental health and substance abuse benefits. Although the rules indicated that this was a reasonable interpretation of the statute, it was decided that this should not be continued going forward. Instead, the same deductible must apply to both medical benefits and mental health and substance abuse benefits. Considering the administrative complexity of integrating deductibles, Anthem is determining the processes and any additional costs that will be applied if carve-out benefits are allowed. How do the rules impact utilization management? The rules generally provide that utilization review criteria cannot be more stringent for mental health and substance abuse than for medical benefits. However, the rules do recognize that there may be clinically appropriate reasons for some differences to exist. Group health plans cannot use EAP programs as a first level of care befo
