Essential health benefit

Coalition for Whole Health Comments on the Proposed EHB Rule

The Coalition for Whole Health (CWH) recently prepared comments in response to the Essential Health Benefit proposed ruleThe CWH comments on the EHB rule can be found here.

If your organization would like to sign on to the attached comments, please email Sherie Boyd ( by no later than the end of the day next Thursday, December 20thPlease forward these comments to your networks and encourage them to sign on as well.

We also strongly encourage all the individual CWH member organizations and their state affiliates to submit their own comments.  Comments should be submitted through and are due by December 26th.   Please feel free to use the above-linked comments as a template for your organization’s comments and encourage your affiliates to do the same.  There is enormous interest in the EHB from across the healthcare system, and we need to generate as many comments from the MH/SUD fields as we can to make sure our issues will be addressed.

If you have any questions, please contact Gabrielle de la Gueronniere ( at 202-544-5478.


EHB Toolkit for State Advocates:

The Coalition for Whole Health (CWH) recently prepared materials to help state advocates response to the Essential Health Benefit proposed rule. We hope the below materials are helpful!

Action Alert on the Proposed EHB Rule with Sample Comments

Checklist for State Benchmark Plan Analysis

EHB Tool for MH and SUD Coverage

Your State’s Benchmark Plan Has a More Limited Scope of Services for MH/SUD than Services Covered for Other Illnesses

Your State’s Benchmark Plan Doesn’t Include Good Coverage of Medications for MH and/or SUD

Your State’s Base-Benchmark Plan Applies More Restrictive Treatment Limitations and Financial Requirements on MH/SUD Services than Other Covered Medical/Surgical Services

Your State’s Base-Benchmark Plan Excludes Residential Substance Use Disorder (SUD) Treatment

Your State’s Base-Benchmark Plan Excludes Methadone for Opioid Addiction Treatment

If you have any questions, please contact Gabrielle de la Gueronniere ( at 202-544-5478.


Federal Government Guidance and other Related Materials on the EHB:,

Center for Consumer Information and Insurance Oversight (CCIIO) “Essential Health Benefits Bulletin,”

CMS: “Frequently Asked Questions on Essential Health Benefits Bulletin,”

“Selected Medical Benefits: A Report from the Department of Labor to the Department of Health and Human Services,”

ASPE Issue Brief: “Essential Health Benefits:  Individual Market Coverage,”

ASPE Research Brief: “Essential Health Benefits: Comparing Benefits in Small Group Products and State and Federal Employee Plans,”

Actuarial Value and Cost-Sharing Reductions Bulletin,

Institute of Medicine recommendations,

SAMHSA’s “Description of a Good and Modern Addictions and Mental Health Service System,”


Coalition for Whole Health Materials on the EHB:

“Coalition for Whole Health tool for evaluating coverage for mental health and substance use disorders in benchmark plan options.” Essential Health Benefit tool for MH and SUD coverage

Coalition for Whole Health comments on the EHB Bulletin:

Coalition for Whole Health, “EHB Consensus Principles and Service Recommendations,”

Milliman Report on Essential Behavioral Health Benefits,

Coalition for Whole Health Comments to the IOM Essential Health Benefits Panel,


Helpful Resources:

Health Affairs Health Policy Brief, “Essential Health Benefits,”

State Progress on Essential Health Benefits:

Alliance for Health Reform Briefing, “Essential Health Benefits:  Balancing Affordability and Adequacy,”

Commonwealth Fund, “Essential Health Benefits:  Balancing State Flexibility with Consumer Protections,”

Letter to Secretary Sebelius from Democrat Ranking Members of House Committees of Jurisdiction on health care,

Timothy Jost, “Implementing Health Reform:  Essential Health Benefits and Medical Loss Ratios,”

HIV Medicine Association Comments on Essential Health Benefits Bulletin,

  • Coalition Documents