Thrift Shop: How Narrow Networks With High Quality Can Win Mental Health Parity...
Part IV of my advice to the department of labor
Welcome to the leading source of hip-hop-related regulatory guidance from your Beloved OpenCommentOutsider.com. The tunes you love and guidance for federal regulators! This series about mental health parity intends to get you, dear readers, to email the Department of Labor and request they do things right.
MHPAEA COMMENTS? Send those comments via email to mhpaea.rfc.ebsa@dol.gov.
Yes, you can forward these articles.
The story thus far:
Part I: Destiny’s Child: Say My Name1
Part II: Shaggy: “Say It Wasn’t You.”
Part III TLC: No Scrubs
Now, in an attempt to focus on the crucial issue of narrow networks in Self Funded Plans that should cost less and be more effective by design:
Today, Macklemore and Ryan Lewis are our inspiration for Mental Health Parity Education!
Much health insurance isn’t paid for by an insurance policy in America. Many employers have realized this is a phenomenally expensive way to pay for routine care, so they don’t. This is referred to as self-funding. I’m a fan—they have aligned incentives with patients and doctors, in my mind! They essentially have no incentive to see costs go up! And costs going up endlessly is the root of all evil in healthcare in America…Self-Funded plans are savvy shoppers for health care services, much like our protagonist, Macklemore:
I'm gonna pop some tags Only got twenty dollars in my pocket I, I, I'm hunting, looking for a come-up This is fucking awesome
I mean, it is not quite as awesome as thrift stores. Thrift stores, as Macklemore points out, have a variety of low-cost options one could consider for fashion:
I'm just pumped, just bought some shit from the thrift shop Ice on the fringe, it's so damn frosty The people like, Damn! That's a cold ass honkey. Rollin' in, hella deep, headin' to the mezzanine Dressed in all pink, 'cept my gator shoes, those are green Draped in a leopard mink, girls standin' next to me
In the world of health benefits, the buyer should beware—not all products that advertise wellness and value provide it…
Probably shoulda washed this, smells like R. Kelly's sheets (Piss) But shit, it was ninety-nine cents!
Unlike thrift store purchases, health benefits buyers are like sending someone else to the store for you who has a legal duty not to buy anything that is not in your best interest:
They be like, Oh, that Gucci. That's hella tight I'm like, Yo that's fifty dollars for a T-shirt Limited edition, let's do some simple addition Fifty dollars for a T-shirt, that's just some ignorant bitch (Shit) I call that getting swindled and pimped (Shit) I call that getting tricked by a business That shirt's hella dope And having the same one as six other people in this club is a hella don't Peep game, come take a look through my telescope Trying to get girls from a brand? Then you hella won't Then you hella won't
Even Seattle-Based Rappers Get It—don’t get tricked by a business!
If only benefits brokers and employers were as serious about avoiding scams and bad deals, no matter how appealing.
I wear your granddad's clothes!
I look incredible
The Department of Labor, in its attempt to enforce mental health parity under CAA, notes some questions for clarification:
Self-insured plans would work with their TPAs and other service providers, … to obtain these data to include in their comparative analyses…
The data comes at the TPA Level, DOL; thanks for asking. The crucial detail for the DOL is that the dearth of in-network options for their self-funded plans isn’t something they want! This is not immediately obvious.
There are NQTLs (cheating) in BIG HEALTH plans because it is profitable to deny mental health care. Poor mental health is a driver of worse general medical health:
I won’t get into the weeds, but according to the Validation Institute, psychiatric illness like depression leads to a 44% increase in general medical spending.
Big Health Insurance is making around 20% profits on total spending by law—the medical loss ratio.
Creating barriers to mental health care—NQTLs—is the product that drives profits for major payers. This is why they cheat. Otherwise, they would be thrilled to drive costs up, making the whole machine even more profitable than the 1% of all the money on earth every year it already costs.
Denying medical care that might drive costs down IS THEIR PRODUCT.
Mental Health Professionals have to deal with the Equivalent of “Prior Authorization for Parachutes” on the most cost-effective and life-saving treatment in medicine and the next generation because it would make BIG HEALTH lose money. Obesity medicine like semeglutide is projected to cost 15% of all American Health Care Spending. That is 4.6 Trillion Dollars. I’ll write that out:
$690,000,000,000.00 is the Revenue for Big Health from GLP-1s.
So anything that gets in the way of that spending going up—our money, our employer’s money, our publicly traded stock value hit’s money—can not be allowed. Inaccessible mental health care leads to prescribing things that cause weight gain:
After that brief aside, back to what to do about Mental Health Parity for Self-Funded Employers Advice for the DOL: Your Safe Harbor Plan is good!
The goal of the future potential enforcement safe harbor would be to promote equal access for participants, beneficiaries, and enrollees to in-network MH/SUD benefits as compared to in-network M/S benefits. The potential enforcement safe harbor would allow plans and issuers flexibility in developing their provider networks (i.e., not requiring exactly the same number of MH/SUD and M/S providers) while ensuring access to MH/SUD benefits is comparable to access to M/S benefits.
I have previously ripped on safe harbors as applied to PBMs, but they serve their legitimate purpose in this case. Safe Harbor from prosecution should be granted if data supports the intention!
My argument: Self-Funded Employers should have to PAY FOR (in the conceptual sense) their safe harbor protections with OUTCOMES DATA that support their good intentions. It’s a get-out-of-jail card! It should not “come cheap”—that would be at the expense of their own plan members.
“Parity” was a terrible way to define law in the first place.
No one wants only parity if it’s two comparable things that suck.
You can have Shakara She Wolf Parity:
And the following would meet strict enforcement standards even on a shot-by-shot basis:
At the same time, we can probably admit those two videos serve different purposes.
Dear Regulators, we need to admit that having mental health care be the same level terrible isn’t the goal of MHPAEA. It was a STRATEGIC choice that big health has exploited to the hilt with NQTLs!
The meaningful version of compliance isn’t just comparable. It’s mentally well people because they were able to get help or had illness prevented in the first place. The safe-harbor pass shouldn’t be based on claims data reporting or compliance—they should be able ALSO to report outcomes data. And if the outcomes are better, who cares if the number of providers is less? Fewer providers doing great work is the actual point of efficient health care.
The safe harbor around MENTAL HEALTH PARITY should only be granted if the plan members get BETTER OUTCOMES.
No one wants access to healthcare. We want to be so well taken care of that we never need that care again. I love never having to see a patient again!
Effective mental health care is like a great cover song. It shouldn’t just be “the same” as the original tune—it should earn its keep by being remarkable.
Macklemore Understands This. (Thrift Shop starts at 6:05).
This is the kind of thing we say about our mental health solutions! Not they are just as good as a horrible prior auth nightmare in general medicine.
Please send comments via email to mhpaea.rfc.ebsa@dol.gov.
(in fairness, I doubt we are ready for destiny, but that is where we are, I suppose…)
So true👏