A recent move by Blue Cross Blue Shield of Florida (BCBSF) has resulted in the termination from provider panels of most in-network mental health and substance use disorder clinicians, and it may violate the federal mental health parity law, wrote APA and its Parity Implementation Coalition partners in an August 25 letter to BCBSF executives.
According to the coalition, BCBSF's announcement that it will be partnering with New Directions Behavioral Health, based in Leawood, Kan., has led to serious concerns about the future of both plan participants and the insurer's mental health and substance use disorder specialist network.
In its letter to BCBSF, the coalition noted that the specialist network was terminated with limited notice and that mental health care providers were subsequently asked to sign new contracts with more restrictive standards and reduced reimbursement rates. The coalition expressed concern that these changes may limit provider participation and availability, reducing patients' access to in-network providers and increasing their reliance on more costly and administratively burdensome out-of-network care.
The letter also outlined how the coalition believes that BCBSF's changes conflict with the interim final rule on the mental health parity law that went into effect at the beginning of the year. Specifically, the coalition voiced concern that BCBSF's new plan applies certain "nonquantitative treatment limitations" to mental health and substance use disorder benefits that are not comparably applied to other types of medical benefits. These limitations include standards for provider admission to participate in a network; plan methods for determining usual, customary, and reasonable charges; and medical-management standards.
The coalition concluded its letter with a list of 10 specific questions and requests regarding BCBSF's network practices and standards.
The questions addressed issues such as whether the newly proposed contractual requirements are similar to those for medical and surgical providers, as well as how the aggregate proposed percentage reimbursement reduction for the inpatient and outpatient mental health and substance use disorder network will compare with the prior fee schedule. Another question concerned the policy on use of, and billing and payment for, the general evaluation and management CPT codes by qualified specialty practitioners.
At press time, the coalition had received a reply letter from BCBSF asserting that the company is "in compliance with all applicable parity laws and regulations." APA and its coalition partners are in the process of formulating their response.
