HHS Making Behavioral Health Care & Coverages Accessible in 2024

On December 12, 2022, HHS released (Payment Notice) for 2024, including key provisions to make access to quality healthcare services accessible, upgrade the plan selection process, and introduce easy ways to enroll in coverages.

The Biden administration has been efficiently working to improve access to healthcare for all Americans, including those who require mental health and substance use treatment. As part of this effort, the administration recently released the Notice of Benefit for 2024, which includes several important behavioral healthcare parameters and coverage provisions.

Furthermore, in collaboration with CMS, HHS aims to improve insurance coverage and reduce the stigma associated with seeking help for behavioral health issues.

With this in mind, let’s discuss what else is included in the proposed rule;

What does the Proposed Rule aim for?

CMS Administrator Chiquita Brooks-LaSure shared thoughts on the role of the proposed rule saying, “We know that access to affordable health care is a concern across the nation. During the first several weeks of Affordable Care Act Marketplace Open Enrollment, we have already seen 5.5 million people select a Marketplace health plan, an 18% increase compared to last year”

Overall, the Proposed Rule for the Notice of Benefit and Payment Parameters for 2024 targets to improve access to affordable and high-quality health care for all Americans, particularly in mental health and substance use treatment, out-of-pocket costs, and protections for people with pre-existing conditions.

Now that we’ve discussed Proposed Rule highlights thoroughly, let’s take a closer look at the key provisions included in the Notice of Benefit 2024 and the impact they could have on individuals and families across the country.

Key Provisions of Notice of Benefit 2024 by HHS

The Notice of Benefit and Coverage for 2024, released by HHS, includes several key provisions to improve Americans’ healthcare access. Some of them are mentioned below;

1.Expanding access to mental health and substance use treatment

The notice includes several provisions aimed at expanding access to mental health and substance use treatment services. For example, it proposes to require health plans to cover certain behavioral health services, such as peer support services and assertive community treatment, and to provide additional resources for mental health and substance use treatment.

In this regard, these provisions will be encouraging providers to extend their participation for up to 35% in ECP categories. It will result in increasing Network Adequacy requirements, grow health equity, facilitate consumers with low income, and attend maximum chronic healthcare conditions in the underserved areas.

2.Increasing access to affordable coverage

Expanding access to affordable coverage, such as establishing a new special enrollment period for people who are uninsured or have recently lost coverage, and expanding access to premium tax credits will be covered in the Notice of Benefit 2024.

Additionally, it also proposes to maintain the user fee rate for health insurers participating in the federally facilitated marketplace at 2.25% of premiums, which is the same rate as in previous years. This user fee rate is lower than the maximum rate allowed by law, which is 3.0% of premiums.

Overall, the user fee provisions aim to support the operation of the federally facilitated marketplace and other ACA-related programs by charging health insurers participating in the marketplace a fee based on the premiums they collect.

3.Better transparency and consumer protection

To smoothen the process of transparency and consumer protections, insurers will provide more detailed information about the costs and benefits of their plans and strengthen protections for people with pre-existing conditions.

In the future, CMS will be investigating to ensure marketplace insurers in FFM and SBM states use accurate healthcare plan names that match the services covered in the plan.

4.Enhancing standard plan selection process

Under the Proposed Rule, health insurers offering plans on the individual and small group markets must provide a standardized plan, known as a “standardized option,” in addition to any other programs they offer. The standardized option is designed to make it easier for consumers to compare plans and understand the benefits and costs associated with each plan.

The rule also includes limitations on non-standard plans, which do not meet the requirements of the standardized option. For example, health insurers will be required to limit the availability of non-standard programs to a certain percentage of their total enrollment based on the state in which the plan is offered. Such approaches will prevent health insurers from offering plans with limited benefits or high cost-sharing that could confuse or mislead consumers.

5.Streamlining financial assistance and enrollment process

CMS believes streamlining the financial assistance and enrollment process for consumers is essential. That’s why they have made changes to ease coverage enrollment and provide transparency in the financial matters. Some of the proposed changes are mentioned below;

A consumer will be ineligible for advanced premium tax credits (APTCs) when he fails to reconcile taxes (FTR) for two consecutive years.
Enrollees will be given time to gather income data and accept attestation instead to help then avail services in the meantime.
In case when qualified enrollees lose coverage mid-month can reactivate it at the beginning of the lost coverage month.
In the Special Enrollment Period, the marketplace is encouraged to implement a new rule for enrollees losing Medicaid or CHIP coverage. It will provide opportunity to the consumers to select a marketplace plan 60 days before and 90 days after losing Medicaid and CHIP coverage.

6.Protecting Consumers And Empowering Personalized Assistance

CMS will now be more focused on improving personalized assistance and protecting health rights of consumers. Here are some key points that CMS will be implementing in 2024;

Encouraging door to door education

The proposed rule would allow certified application counselors (CACs) and navigators to conduct outreach and enrollment activities in-person, including door-to-door assistance. Such activities will result in better engagement and will improve health equity for the consumers.

Safety and training

The proposed rule includes requirements for CACs and navigators who provide door-to-door assistance to ensure the safety of both the enrollment assisters and the consumer. It also emphasizes the importance of providing adequate training to these individuals to ensure that they are equipped to provide accurate and helpful information.

Regulating health equity

Notice of Benefit emphasizes the importance of promoting health equity and reducing disparities in healthcare access and outcomes. Door-to-door assistance is one strategy that can be used to reach underserved populations and ensure that they have access to healthcare coverage.

Policies for agents and brokers

CMS has passed several rules for marketplace agents and brokers when receiving complaints from the consumers. Brokers, agents and other webrokers will take proper consent from the consumers (authorized representative) before enrolling them in any coverage plan. Furthermore, an authorized representative or the consumer himself will review the accuracy of the eligibility information before submitting an ap[plication for a specific coverage plan.

Conclusion

HHS new provisions based on Notice of Benefit containing information about plan premiums, deductibles, copayments, and coinsurance, as well as information about covered benefits and prescription drug coverage. It also includes information about financial assistance programs, such as premium tax credits and cost-sharing reductions, that can help make coverage more affordable for eligible individuals and families.

Additionally, CMS has emphasized the importance of promoting health equity and reducing disparities in healthcare access and outcomes, which will be a key focus in future iterations of the Notice of Benefit. In the future they aim to help individuals and families make informed decisions about their healthcare coverage, and it is important that it provides clear, accurate, and accessible information to ensure that everyone has access to affordable healthcare.

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