6 Recommendations for Mental Health Network Adequacy

"Implementing robust network adequacy requirements is an underutilized tool. Failing to address network adequacy undermines other policy initiatives to expand access to affordable care," says the Legal Action Center.

In October, California became the latest of seven states to mandate that payers reduce wait times for member access to mental health services. But the new law highlights challenges linked to existing federal requirements that remain unmet and often unenforced: provider shortages, network adequacy, and reimbursement parity. As payers seek to make strides, they do so against the backdrop of recommendations from the Legal Action Center (LAC)'s most recent report on network adequacy for mental health and substance abuse disorder (MH/SUD) services.

The LAC recommends the following:

1. Standardized network adequacy measurement: Specific metrics for network adequacy that include accessibility and availability to "create greater accountability and uniformity across health plan."
    
2. Specific MH/SUD metrics: To "address historical discriminatory insurance coverage for these services, the LAC recommends metrics that "cover the full range of MH and SUD practitioners and facilities and that quantitative measures for geographic distance, wait time and provider/enrollee ratios align with those for primary care physicians and comparable medical facilities."
    
3. Payer cost-share: To address adequacy and out-of-network care's higher costs, the LAC recommends that states require coverage parity with in-network services.
    
4. More transparency: Including the filing and/or public availability of payer access plans, compliance results, and contracting criteria along with required, continuous monitoring programs.
    
5. More education: LAC advises that consumers "need to be better informed when selecting a health plan about the carrier’s provider network and the trade-offs associated with plans that offer lower premiums for limited plan networks."
    
6. Ongoing oversight: To include enforcement and corrective action.
    

The LAC's report includes specific state callouts as well. In addition to the states with wait time laws—Colorado, Maine, Maryland, Missouri, New Hampshire, Texas, and now California—a dozen have travel time/distance requirements specific to MH/SUD.

LAC's diverse recommendations are tied to its identification of "other factors that contribute to inadequate networks." These include: the lack of available providers, lower rates of pay, balance billing, and provider directory quality.