The current Substance Abuse and Mental Health Services Administration (SAMHSA) Acting Administrator Kana Enomoto stepped into the role in August with the departure of Pamela Hyde. Enomoto previously served as the principal deputy administrator. In this capacity, she was the principal advisor on operations, policies and programmatic activities for the agency.
With 15 years of public service behind her, Enomoto continue to be a strong influence as she makes significant contributions to policy development that guides our country’s behavioral health services. She and her team hold the organizational memories that will keep us from repeating past errors.
SAMHSA has over 600 employees and a budget of $3.6 billion. Through policy, public education and grants, the SAMHSA team advances the agency’s mission to reduce the impact of substance abuse and mental illness on America’s communities. Enomoto is well qualified for the job. She holds a master’s degree in psychology and is a graduate of Harvard University’s Kennedy School of Government.
I sat with Kana recently and asked for her perspective on the progress of behavioral health parity. It was two years ago that the Departments of Treasury, Labor, and Health and Human Services (HHS) issued a final rule implementing the 2008 Mental Health Parity and Addiction Equity Act (MHPAEA).
Where are we now and what are the next steps?
Enomoto: HHS and the Departments of Labor and Treasury have undertaken a variety of efforts in support of the implementation of MHPAEA following the release of the final rule. These include enforcement activities and efforts to educate the public and stakeholders about MHPAEA and the related regulations.
Have you gotten any feedback from stakeholders?
Enomoto: SAMHSA, working closely with the Department of Labor, has solicited feedback from stakeholders on federal enforcement activities and outreach efforts. The agencies held a series of conference calls between March and May of 2015 with consumer groups, insurers, providers, and substance use and mental health stakeholders. SAMHSA and the Department of Labor now are developing additional parity outreach materials as a result of these discussions and the feedback we received about parity compliance and communication efforts.
Does the outreach material that’s being developed reach the level of the consumer?
Enomoto: Good question, and yes it will. Specific information is being developed that will guide individuals as well as providers in seeking the services that they and their family members are entitled to under MHPAEA as well as information about compliance and enforcement.
Have you had to develop further rules to clarify some of the more confusing aspects?
Enomoto: HHS is working on additional rulemaking to clarify the application of MHPAEA. The regulations regarding MHPAEA developed for the commercial market did not apply to Medicaid and the Children’s Health Insurance Program (CHIP). In January 2013, the Centers for Medicare and Medicaid Services (CMS) issued a State Health Official (SHO) letter that provided initial guidance to states regarding the application of MHPAEA to Medicaid Alternative Benefit Plans, Managed Care Organizations, and CHIP. The guidance in the SHO required states to comply with the MHPAEA statute when applying parity to the three impacted Medicaid authorities.
In April of 2015, CMS issued a Notice of Proposed Rulemaking applying MHPAEA to Medicaid and CHIP. The rule is entitled Medicaid and Children's Health Insurance Programs; Mental Health Parity and Addiction Equity Act of 2008. This proposed regulation aligns where possible with the final 2013 regulations for the commercial market and identifies areas where Medicaid policy is different than policies affecting the commercial market, warranting distinct regulatory guidance.
Also important is CMS’s proposed rule regarding Medicaid managed care, CHIP delivered in managed care, Medicaid and CHIP comprehensive quality strategies, and revisions related to third party liability. Issued in June 2015, the proposed rule, when finalized, will improve services for individuals receiving Medicaid services through managed care, including behavioral health.
Can you tell us who commented on the proposed Medicaid parity rule?
Enomoto: Comments on the proposed Medicaid parity rule can be viewed at regulations.gov. Commenters included advocates and consumer organizations, states, managed care organizations, providers and professional associations. HHS also received a handful of comments from private individuals. HHS is working toward the publication of a final rule in order to guide states in the implementation of this important law.
If someone is interested in looking further into MHPAEA, where would they look?