IA--Northeast Iowa Behavioral Health, Inc.

February 20, 2013
Marilyn Tavenner, Acting Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
7500 Security Boulevard
Baltimore, MD 21244
RE: CMS-2334-P, Medicaid, Children’s Health Insurance Programs, and Exchanges: Essential Health Benefits in Alternative Benefit Plans
Dear Administrator Tavenner:
I appreciate the opportunity to comment on the proposed rule detailing standards related to essential health benefits in Medicaid alternative benefit plans. I appreciate your strong commitment to making mental health (MH) and substance use disorders (SUD) a top priority and for working to ensure that Medicaid enrollees with MH/SUD needs receive quality care. I am the Director of a CMHC that provides mental health and supbstance abuse treatment in rural Iowa. Many of the individuals we serve are un or under insured and face financial problems in addition to addiction, mental health and other issues. Accessing quality and affordable care is a challenge that we recognize and work to alleviate with limited resources.
It is extremely important that all individuals gaining Medicaid eligibility under the Affordable Care Act (ACA) receive health coverage appropriate for their needs, including strong coverage for mental health and substance use disorders. It is also important that traditionally Medicaid eligible populations that may be enrolled in alternative benefit plans are guaranteed adequate coverage. The chance to significantly improve quality of life and support recovery is immeasurable.
I appreciate the proposed rule’s explicit recognition of the ACA requirement that alternative benefit plans must provide the benefits required by the EHB, including MH and SUD benefits in a manner consistent with the requirements of the Mental Health Parity and Addiction Equity Act (MHPAEA). I recognize the importance of CMS continued recognition of these critically important ACA requirements.
I also apprec