From: Gass, Michael
To: Parity Task Force (HHS/ASPE)
Subject: Comments on "Strategies for parity for mental health and substance use disorder coverage"
Date: Friday, August 04, 2017 4:10:52 PM
August 4, 2017
Laurel Fuller
ASPE
200 Independence Ave. SW. Room 424E
Washington DC 20201
Dear Ms. Fuller,
I am writing this letter in lieu of oral comments delivered on July 27, 2017 on "Strategies for Improving Parity for Mental Health and Substance Use Disorder Coverage.” I am a professor in the College of Health and Human Services at the University of New Hampshire and Director of the Outdoor Behavioral Healthcare Research Center located at UNH. In a time when substance abuse and mental health issues are a growing concern in our nation, every avenue of evidence-based therapeutic techniques need to be employed. I would encourage you to recognize the growing effectiveness of outdoor behavioral healthcare programs in the treatment of these issues.
Outdoor behavioral healthcare needs to be recognized as a valid intermediate behavioral healthcare intervention. It is already recognized by the National Uniform Billing Committee (NUBC) and the AHA for purposes of claims insurance and other treatment venues. The best of these programs are fully licensed, certified, and accredited by the most stringent standards in the profession. Research from our Center has focused on demonstrating appropriate risk management, best practices, evidence-based outcomes, and accreditation. When all of these features are combined together, clients are experiencing positive gains, often when no other form of treatment has been successful. I would invite you to peruse our website and the evidence-based practices it presents along with other professional attributes. http://obhrc.org
It would be beneficial for the MHPAEA to include all intermediate levels of care, not just Residential Treatment so that parity can be applied equally for all intermediate levels of care. While many payers are willing to fund these other types of non-residential programs, many still exclude this type of intervention. Appeals of these non-covered denials are time consuming and costly to consumers.
I welcome your feedback and interests in outdoor behavioral healthcare.
Sincerely,
Michael Gass, Ph. D., LMFT Professor
Department of Kinesiology
College of Health & Human Services
NH Hall, 124 Main Street University of New Hampshire
Durham, NH 03824
Office phone: 603-862-2024
Fax: 603-862-0154
email: mgass@unh.edu
