Coalition for Whole Health

Comments to CMS on single streamlined application data elements

admin — Tue, 13 Nov 2012 18:56:20 +0000

In September, 2012, the Coalition for Whole Health submitted comments to CMS on their proposed data elements for the single, streamlined application for Exchange credits, Medicaid, and SCHIP.

Read the comments here.

The comments thank CMS for simplifying the application to only include the minimum that is required to determine eligibility. The comments also thanked the Department for its commitment to ensuring a simple and straightforward application experience.

Comments to CMS on Medicaid State Plan Home and Community-Based Services

admin — Tue, 13 Nov 2012 18:50:31 +0000

In July, 2012, the Coalition for Whole Health submitted comments to CMS on their proposed rule related to the Section 1915(i) Home and Community Based Services (HCBS) State plan option.

Read the comments here.

Section 1915(i) provides an important opportunity for States to provide home and community-based services to Medicaid beneficiaries with mental health and/or substance use disorder needs. The comments thanked CMS for issuing the proposed rule and gave recommendations to CMS on how to use this option to improve care for those Medicaid beneficiaries with serious mental illness and/or substance use disorders in need of home and community based services.

Comments on proposed rule related to data collection to support standards related to Essential Health Benefits

admin — Tue, 13 Nov 2012 18:47:31 +0000

In July, 2012, the Coalition for Whole Health submitted comments to HHS on the data collection standards necessary to implement the Essential Health Benefits requirements of the ACA.

Read the comments here.

The comments asked HHS to ensure that arbitrary and unreasonable benefit limits are not incorporated into the EHB, and asked HHS to collect data regarding standards for defining medical necessity and coverage exclusions. The comments also asked HHS to develop and implement a parity compliance audit for all qualified health plans and to reiterate that all ten EHB categories must be covered regardless of the approach taken by states.

Comments to CCIIO on guidance related to Federally-facilitated Exchanges

admin — Tue, 13 Nov 2012 18:42:47 +0000

In June, 2012, the Coalition for Whole Health submitted comments to the Center for Consumer Information and Insurance Oversight at CMS on their bulletin on Federally-facilitated Exchanges.

Read the comments here.

In the comments, the Coalition urged CCIIO to reiterate their commitment that consumers in states with a Federally-facilitated Exchange will receive the full range of ACA protections afforded to consumers in states that operate their own Exchanges. The comments also urged CCIIO to work closely with stakeholders in the states where they are implementing Federally-facilitated Exchanges and to closely monitor state performance in states operating Partnership Exchanges.

CWH comments to the Patient-Centered Outcomes Research Institute on their national priorities for research

admin — Tue, 13 Nov 2012 18:38:55 +0000

In March, 2012, the Coalition for Whole Health provided comments to the Patient-Centered Outcomes Research Institute on their proposed research agenda.

Read the comments here.

The comments the Coalition submitted to PCORI focused on the need for a strong commitment to research into chronic diseases, including mental health and substance use disorders. The comments encouraged PCORI to include in its funding priorities strong support for MH/SUD intervention and service system research and programming related to PCORI’s priorities and goals.

Comments on proposed rule related to data collection to support standards related to Essential Health Benefits

admin — Thu, 08 Nov 2012 22:54:49 +0000

In July, 2012, the Coalition for Whole Health submitted comments to HHS on the data collection standards necessary to implement the Essential Health Benefits requirements of the ACA.

Read the comments here.

Milliman Report on Essential Behavioral Health Benefits

admin — Fri, 24 Feb 2012 18:02:57 +0000

In December 2011, the Coalition for Whole Health released a report by Milliman analyzing the MH/SUD benefits that are typically covered by employer sponsored health insurance. The report shows that large group health plans typically cover a broad spectrum of benefits for MH and SUD.

A copy of the report can be found here: CWH final report 12-15-2011

Comments on EHB Bulletin

admin — Fri, 27 Jan 2012 21:48:25 +0000

In January 2012, the Coalition submitted its final comments on the Essential Health Benefits Bulletin.

We encourage the MH/SUD field to submit as many independent comments as possible. Please feel free to use the Coalition’s response as a template for your organization’s own comments, and please forward the attached to your networks and encourage them to do the same.

Read the Coalition’s comments here.

EHB Consensus Principles and Service Recommendations

admin — Fri, 27 Jan 2012 21:39:19 +0000

In January 2012, as the federal Department of Health and Human Services (HHS) develops final guidance on EHB and state policy-makers move forward with ACA benefit design, the Coalition finalized recommendations to fully include mental health and substance use disorder services within the Essential Health Benefits framework of the Affordable Care Act.

Read the recommendations here.

Letter to HHS Secretary Asking for Data, More Comment Time

admin — Fri, 27 Jan 2012 20:49:26 +0000

In January 2012 the CWH — including over 75 national, state and local groups in the SUD and MH communities — submitted a letter to HHS Secretary Kathleen Sebelius asking for the data HHS used to develop the Essential Health Benefit Bulletin, and for more time to provide comment.

Read the full letter here.