WASHINGTON—Robust access to quality mental health and substance use disorder services could be jeopardized due to a proposed rule from the Departments of Labor, Health and Human Services, and the Treasury, according to comments submitted by the Blue Cross Blue Shield Association (BCBSA).

The comments on the proposed regulations which update the implementation of the Mental Health Parity and Addiction Equity Act asserted that the new requirements could increase care that is not clinically recommended, ultimately leading to poorer health outcomes. The rule could also limit a patient’s ability to choose an approach to care that best suits their needs resulting in fewer patients seeking help.

“We share the administration’s goal of expanding access to affordable mental health support, but we’re concerned it could become harder—not easier—for patients to get the care they need,” said David Merritt, BCBSA’s senior vice president of policy and advocacy. “This rule could push us in the wrong direction by forcing health plans to remove important protections that ensure patients are receiving safe, medically necessary, effective care. We’ll continue to work with our partners, the administration and Congress to improve both access and quality for Americans.”

BCBSA is committed to working with providers and policymakers to address short- and long-term challenges with access to mental health care. Provider shortages is one of the key barriers to access. To work toward a more robust mental health workforce, BCBSA recommends:

• Expanding quality assurance and oversight for non-clinical personnel to fully engage these personnel in the workforce and better support diverse member needs.
• Expanding access to tele-mental health services and allowing behavioral health providers to practice across state lines to meet patients where they are regardless of their geography.
• Promoting diversity in the long-term workforce pipeline by creating pathways for high school and community college students to become behavioral health professionals so patients can find the provider that is right for them.

Blue Cross and Blue Shield companies are already building innovative benefits that prioritize early detection and treatment; maintaining and expanding high-quality, comprehensive behavioral health networks; and attracting provider participation to support the broader populations and communities they serve.

In addition to having one of the largest provider networks with 96% of all providers in network, there has been steady growth in the number of mental health and substance use disorder providers added to BCBS networks nationwide—which has grown 55% since 2019.

Additionally, BCBSA recently partnered with the Boys & Girls Clubs of America to implement trauma-informed practices in more than 5,000 Clubs across the country, reaching more than 3 million children.

“Our commitment is simple—everyone deserves affordable access to quality mental health care, no matter who they are or where they live. We look forward to working with our partners to implement these commonsense solutions that allow people to live their healthiest lives,” continued Merritt.