BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  SB 22
                                                                  Page  1

          Date of Hearing:   August 14, 2013

                        ASSEMBLY COMMITTEE ON APPROPRIATIONS
                                  Mike Gatto, Chair

                      SB 22 (Beall) - As Amended:  July 2, 2013 

          Policy Committee:                             HealthVote:17-2

          Urgency:     No                   State Mandated Local Program:  
          Yes    Reimbursable:              No

           SUMMARY  

          This bill requires health plans and insurers to report to the  
          Department of Managed Health Care (DMHC) and the Department of  
          Insurance (CDI), respectively, on compliance with state and  
          federal law related to mental health parity. Specifically, this  
          bill:

          1)Requires reports to be submitted annually on and after October  
            1, 2014.

          2)By July 1, 2014, requires DMHC and CDI to jointly create  
            reporting standards that are standardized and intercomparable.

          3)By January 1, 2020, requires DMHC and CDI to report to the  
            Legislature on the information contained in reports, as well  
            as a summary of related regulatory actions.

          4)Requires plans and insurers to conduct surveys of  
            enrollees/insured and providers for inclusion in reports.

          5)Exempts managed care plan contracts that serve Medi-Cal  
            enrollee from the bill's requirements.

           FISCAL EFFECT  

          1)One-time costs to CDI and DMHC in the range of $650,000 total  
            (Insurance Fund and Managed Care Fund) for collaborative  
            rulemaking, development of standards for reporting, and  
            initial review. 

          2)Annual costs of at least $100,000 total to CDI and DMHC  
            (Insurance Fund and Managed Care Fund) for ongoing review of  








                                                                  SB 22
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            filed reports. Costs could exceed this level depending on plan  
            compliance, consumer complaints, and enforcement actions.  For  
            example, if the filed reports raise concerns about the plans'  
            provision of mental health services and the DMHC determines  
            non-routine surveys are required, DMHC could incur contractor  
            costs of up to $75,000 for each survey (Managed Care Fund).

           COMMENTS  

           1)Rationale  . The author indicates that, in spite of the  
            appearance of compliance with federal and state laws requiring  
            mental health and substance abuse services to be treated at  
            parity with medical services, plans and insurers routinely do  
            not actually operationalize the parity laws at the point of  
            service delivery.  He cites examples from both mental health  
            patients and providers that indicate patients with mental  
            disorders are not able to access medically necessary care.   
            Finally, he believes a complaint-driven system is inadequate  
            for enforcement of mental health parity laws because people  
            with mental health disorders are not as likely to file  
            complaints.

           2)Mental Health Parity  . Mental health parity laws generally  
            require that patient financial participation (such as co-pays  
            and deductibles) and treatment limitations (such as visit  
            limits) applicable to mental health or substance use disorder  
            benefits are no more restrictive than the predominant  
            requirements or limitations applied to medical benefits. Under  
            current law, California has had partial mental health parity  
            for specified conditions since AB 88 (Thompson), Chapter 524,  
            Statutes of 1999. AB 88 requires treatment parity for serious  
            mental illness such as schizophrenia, autism, and anorexia  
            nervosa.  

            The federal Mental Health Parity and Addiction Equity Act  
            (MHPEA) of 2008 went into effect on January 1, 2010, and  
            requires group health plans with more than 50 employees that  
            offer both medical and mental health benefits to ensure parity  
            for mental health.  Although interim final rules have been  
            available since February 2010, final rules implementing MHPEA  
            are have not yet been promulgated.  Additionally, the Patient  
            Protection and Affordable Care Act (ACA) requires all plans to  
            cover mental health and substance use disorder services as one  
            of 10 essential health benefits, which is likely to apply  
            parity to additional plans that currently do not cover mental  








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            health and substance use disorder services.  

           3)Opposition  . Health plans and insurers oppose this bill, citing  
            redundancy with current reporting requirements and enforcement  
            authority of regulators. 

           Analysis Prepared by  :    Lisa Murawski / APPR. / (916) 319-2081