Pennsylvania Strengthens Review of Mental Health and Substance Use Disorder Coverage in 2024 Health Plans

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Pennsylvania Acting Insurance Commissioner Michael Humphreys recently announced the Pennsylvania Insurance Department (PID) has strengthened its review of mental health and substance use disorder coverage in 2024 health plans. Insurers under PID regulation must file their plans with the Department for approval. Now, for 2024 filings, PID is enhancing its compliance review of mental health and substance use disorder parity requirements to prevent potential violations before they have a chance to harm Pennsylvania consumers.

“In honor of Mental Health Awareness Month, the Department is focused on how we can best serve Pennsylvanians. As insurers begin to file 2024 plans and rates, the Pennsylvania Insurance Department is ensuring we protect Pennsylvanians before a plan even makes it to market,” said Humphreys. “Under the direction of Governor Shapiro, we are strengthening our review processes to make sure that plan benefits offered to consumers fully realize the benefits of state and federal mental health parity protections.”

Since January, PID has:

  • Strengthened travel time and distance standards for in-network providers. These standards require insurers to maintain provider networks that have in-network providers within a reasonable distance or within a reasonable travel time for consumers.
  • Reviewed large group filings for parity compliance. With these reviews, an additional 1.2 million covered lives will have their benefits reviewed for mental health parity compliance before the policies are available for purchase. PID also reviews all individual and small group health insurance plans for parity compliance.
  • Reviewed parity analyses for student health filings for the 2024 school year. An additional 40,000-50,000 covered lives will have their benefits reviewed for parity compliance before the policies may be sold.
  • Updated its Quantitative Treatment Limitation and Financial Requirement analysis template for insurers. The template assists PID in determining a plan’s compliance with requirements under the Mental Health Parity and Addiction Equity Act. Updating the template improves the Department’s ability to identify cost-sharing or treatment limitations under a plan’s benefits. It also helps the Department to hold insurers accountable by verifying that what is in a plan’s schedule of benefits matches PID’s analysis of the plan.
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The Department pushed insurers to correct parity issues found during the large group and student health filing review process, resulting in insurers correcting 100 percent of the issues identified during the front-end product review. Some of the corrections included requiring insurers to remove session limits for rehabilitative and habilitative therapies when prescribed for mental health, and to provide clearer exclusions of cost-sharing or session limits for mental health services.

“The regulatory oversight processes that the department employs are just a piece of the overall plan to improve mental health and substance use disorder parity in Pennsylvania,” added Humphreys. “We continue to look at other actions we may be able to take, whether prior or after policy approval and sale, and including further consumer outreach and education. Evaluating whether mental health and substance use disorder benefits are covered fairly is a priority at the department, and we will consider every avenue to protect consumers’ rights and access to treatment.”

The department is also urging consumers and providers to contact the Department if they think a health plan is not meeting parity requirements for mental health and substance use disorder coverage or if a consumer has questions about the benefits to which they are entitled.

For more information on the mental health and substance use disorder parity, or to file a complaint or ask a question, visit the department’s Bureau of Consumer Services at or call 1-877-881-6388.

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