Texas Parity Analysis Approach

As required by Mental Health Parity and Addiction Equity Act, when the managed care organization (MCO) does not provide the full scope of services, the state must review the mental health and substance use disorder (MHSUD), and medical and surgical (MS) benefits provided through the MCO and fee-for-service for parity compliance. Though Texas Medicaid is predominantly managed care, the MCO does not provide the full scope of services, and some beneficiaries receive a few services through the fee-for-service delivery mechanism. In this case, HHS — not the MCOs — must assess Medicaid and CHIP programs for compliance with federal parity rules.

In 2017, HHS analyzed the quantitative treatment limitations of its state plan Medicaid benefits for compliance and provided direct oversight of each MCO’s analysis for non-quantitative treatment limitations.

Benefit Packages

For parity compliance, the state identified three benefit packages:

  • Medicaid for adults (age 21 and older)
  • Medicaid for children (birth through age 20)
  • Children’s Health Insurance Program (CHIP)
The Delivery of Benefit Packages by MCOs in 2017

Managed Care Organization

Benefit Package

Children

Adult

CHIP

Aetna

Yes

Yes

Yes

Amerigroup Texas

Yes

Yes

Yes

Blue Cross Blue Shield of Texas

Yes

Yes

Yes

Children’s Medical Center Health Plan

Yes

No

No

Christus Health Plan

Yes

Yes

Yes

Cigna-Health Spring

No

Yes

No

Community Health Choice

Yes

Yes

Yes

Community First Health Plan

Yes

Yes

Yes

Cook Children’s Health Plan

Yes

Yes

Yes

Driscoll Children’s Health Plan

Yes

Yes

Yes

El Paso First Health Plans

Yes

Yes

Yes

First Care

 

Yes

Yes

Yes

Molina Healthcare of Texas

Yes

Yes

Yes

Parkland Community Health Plan

Yes

Yes

Yes

Scott and White Health Plan

Yes

Yes

No

Dell Children’s Hospital Plan

Yes

Yes

Yes

Superior Health Plan

Yes

Yes

Yes

Texas Children’s Health Plan

Yes

Yes

Yes

United Healthcare Community Plan

Yes

Yes

Yes

Defining Medical and Surgical or Mental Health and Substance Use Disorders

HHS used the International Classification of Diseases, Tenth Revision (ICD-10), as the generally recognized standard to make determinations about which benefits are used to treat mental health and substance use disorders. All disorders listed in the F chapter of the ICD-10 with the exception of mental disorders due to known physiological conditions (F01-F09), nicotine dependence (F17) and IQ-related disabilities and disorders (F70-F89) were designated as mental health and substance use disorders. These exceptions and all other disorders in the ICD-10 were classified as medical and surgical conditions.

HHS determined that benefits used to treat a mental health or substance use disorder were considered mental health and substance use disorder benefits; benefits used to treat medical and surgical disorders were considered medical and surgical benefits. If a benefit can be used to treat both mental health and substance use disorder and medical and surgical disorders, then the benefit was listed in both categories. HHS classified each benefit into the inpatient, outpatient or emergency services classification.

HHS used the American Hospital Formulary Service Codes — a nationally recognized standardized system of classification for prescription drugs — to list benefits in the pharmacy classification under the mental health and substance use disorder, medical and surgical disorder, or both categories.

Defining Classifications

To determine which benefits belonged in each classification, HHS considered how the benefit would be claimed and the setting(s) in which the benefit would be delivered. Some benefits, because they can be delivered in multiple settings, were placed in more than one classification. Drugs or drug classes that are on the Texas Medicaid and CHIP Formulary were placed in the pharmacy classification.