Policy Priorities

Our policy priority on Reimbursement Rates and Rate Setting focuses on ensuring fair, transparent, and adequate payment structures that sustain high-quality mental health care access for all. This includes:

• RAE and Commercial Plan Rate Setting: Advocating for equitable reimbursement rates from Regional Accountable Entities (RAEs) and commercial insurers to close gaps that limit provider participation and patient access.

• Contract Disparities: Addressing unequal contract terms that create financial instability and restrict service availability, especially for smaller and community-based providers.

• Rate Setting and Spending Transparency: Pushing for clear, public reporting on how rates are determined and how funds are allocated to foster accountability and informed policy decisions.

• Raising Family and Group Therapy Rates: Supporting increased reimbursement for family and group therapy sessions, recognizing their critical role in holistic mental health treatment and long-term recovery.

• Medicaid Fee-For-Service (FFS) Psych Testing Rates: Working to raise Medicaid FFS rates for psychological testing, ensuring providers can offer comprehensive assessments without financial loss. Although not all providers perform this service, the downstream effect for Medicaid members with ASD and any associated services can be detrimental if not addressed because initial assessments are required for Members to qualify for critical services.

These priorities are top of mind because inadequate or opaque reimbursement systems threaten the sustainability of mental health services, limit provider networks, and ultimately reduce access to essential care for vulnerable populations. By advocating for fair rates and transparency, we aim to build a stronger, more equitable mental health system that meets the diverse needs of our communities.

Our focus on Parity Violations targets the enforcement and strengthening of laws that require mental health and substance use disorder benefits to be treated equally to physical health care coverage. This includes:

• Identifying and Addressing Discriminatory Practices: Highlighting instances where insurers impose stricter limits, higher costs, or more burdensome authorization requirements for mental health services compared to medical care.

• Improving Compliance and Oversight: Advocating for stronger regulatory oversight to ensure insurers follow parity laws, including timely investigations and meaningful penalties for violations.

• Enhancing Transparency: Calling for clear reporting from insurers on how mental health benefits are managed versus physical health benefits to detect disparities early.

• Supporting Consumer Protections: Empowering individuals with resources and advocacy to challenge unfair denials or restrictions on mental health coverage.

• Closing Loopholes: Working to eliminate gaps in parity laws that allow insurers to circumvent equal coverage through narrow definitions or limited provider networks.

Parity violations undermine access to necessary mental health care by creating financial and administrative barriers that do not exist for physical health treatment. Ensuring true parity is essential to dismantling stigma, improving treatment outcomes, and promoting equitable health care for all. This remains a critical priority because without enforcement, parity laws risk becoming ineffective promises rather than real protections.

Our priority on Reducing Administrative Burden and Cost aims to streamline processes so providers can focus more on delivering care and less on paperwork. Key areas include:

• No Prior Authorization (No PAR) Success: We celebrate the victory in maintaining the no prior authorization policy by not repealing SB22-156, which has significantly reduced delays and barriers to timely mental health treatment.

• Addressing Ongoing Administrative Challenges: We actively identify other policies and practices that create unnecessary paperwork, slow reimbursement, or increase costs, and advocate for practical solutions to minimize these burdens.

• Proactive Problem-Solving: When new administrative obstacles arise, we engage with policymakers, insurers, and providers to develop collaborative, efficient fixes that keep mental health care accessible and sustainable.

• Upcoming Batch Insurance Eligibility Verification Tool: We are preparing for the rollout of a robust, compliant, state-of-the-art new tool that will allow batch verification of insurance eligibility for both Medicaid and commercial plans. This innovation promises to save time and reduce errors, with discounted access for MHANCO members to support provider efficiency.

Reducing administrative hurdles is essential to keeping mental health services affordable, accessible, and focused on patient care rather than paperwork. By championing these efforts, we help create a system that works better for providers and the communities they serve.

Our Workforce Development priority is dedicated to building a strong, diverse mental health workforce by supporting clear, accessible educational and licensure pathways across a wide range of roles. This includes:

• Qualified Behavioral Health Associates (QBHA): The Qualified Behavioral Health Associate (QBHA) role was established under Senate Bill 22-181 (SB22-181), which is a recent Colorado legislative effort focused on expanding the behavioral health workforce and creating new pathways for entry-level mental health professionals. The bill was enacted in 2022 and sets the foundation for training, certification, and integration of QBHAs into the mental health system to increase service capacity and support community-based care. We advocate for robust training, certification, and integration of QBHAs to meet growing community needs.

• Bachelor’s Level and Intern Pathways: Promoting educational programs and internship opportunities that prepare individuals at the bachelor’s level for entry into mental health careers, ensuring early career support and skill development.

• Pre-Licensure Support: Facilitating accessible, affordable pathways for mental health professionals in training, including supervision and practical experience requirements, to ease the transition to full licensure.

• Licensure for All Mental Health Professions: Advocating for streamlined, equitable licensure processes across disciplines—such as counseling, social work, psychology, addiction counseling, and marriage and family therapy—to reduce barriers and expand the pool of qualified providers.

Strengthening workforce development is crucial to meeting the rising demand for mental health services. By supporting these pathways, we help create a sustainable, well-prepared workforce ready to provide compassionate, high-quality care to our communities.

Our Insurance Network Transparency priority focuses on ensuring clear, accurate information about mental health provider networks so individuals can access the care they need without unexpected barriers. This includes:

• Network Adequacy: Advocating for strict standards that require insurers to maintain sufficient numbers and types of mental health providers within their networks to meet community needs.

• Transparent Reporting: Calling for insurers to publicly disclose detailed, up-to-date network directories and data on provider availability, wait times, and geographic coverage.

• Addressing Network Gaps: Highlighting and working to close disparities where mental health providers are underrepresented or excluded, which limits access and increases out-of-network costs.

• Consumer Empowerment: Equipping individuals and families with clear information to make informed choices about their insurance plans and providers.

Transparency in insurance networks is essential to dismantling hidden barriers to mental health care. By pushing for openness and accountability, we help ensure that coverage means real access to timely, quality mental health services.

Our priority on Protecting Telehealth for Mental Health centers on safeguarding and expanding virtual care options that increase access, especially for underserved and rural communities. This includes:

• Ensuring Continued Coverage: Advocating for permanent policies that require insurers, including Medicaid and commercial plans, to cover telehealth mental health services at parity with in-person care.

• Supporting Flexible Delivery: Promoting the use of diverse telehealth platforms—video, phone, and other digital tools—to meet varied patient needs and reduce barriers like transportation or mobility challenges.

• Addressing Reimbursement Fairness: Working to establish fair and sustainable reimbursement rates for telehealth services that reflect their value and encourage provider participation.

• Maintaining Privacy and Quality: Ensuring telehealth services meet high standards for patient privacy, security, and clinical effectiveness.

Telehealth has transformed mental health care by making it more accessible and convenient. Protecting these gains is vital to building an equitable, resilient system that reaches everyone, wherever they are.

Our priority to Support Substance Use Disorder (SUD) Providers and Services for Serious Persistent Mental Illness (SPMI) focuses on strengthening the full continuum of care for individuals facing complex behavioral health challenges. This includes:

• Intensive Outpatient Programs (IOP) and Partial Hospitalization Programs (PHP): Advocating for adequate reimbursement and resources to sustain these critical intermediate care levels that provide structured, effective treatment while supporting community integration.

• Inpatient Care: Addressing the need for sufficient inpatient psychiatric beds and services to ensure timely, appropriate care for individuals with severe mental illness and acute substance use crises.

• Provider Support and Workforce Stability: Promoting policies that reduce administrative burdens, improve reimbursement, and enhance workforce training to retain and expand skilled providers in SUD and SPMI care.

• Integrated Care Models: Encouraging coordination between mental health and substance use services to provide holistic, person-centered treatment that addresses co-occurring disorders effectively.

Supporting these providers and care settings is essential to meeting the complex needs of people with serious mental health and substance use challenges, reducing hospitalizations, and improving long-term recovery outcomes.