Comments on Federal Parity Regulations
The Interim Final Regulations (IFR) implementing the 2008 Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act were published in February. The comment period on the regulations expires at 11:59 pm eastern on Monday, May 3rd. It is critical for NAMI state and local affiliates to add their voice to ensuring strong rules implementing federal parity.
The three federal agencies that drafted the regulations – Labor-HHS and Treasury – are required to carefully weigh and measure all comments submitted by interested parties and general public. In fact, the agencies will actually count the umber of comments weighing in on specific issues and recommending specific changes. The comments on the regulations have taken on added importance as a result of a lawsuit filed by health plans against the federal agencies seeking to block enforcement of the regulations and a campaign to undermine specific protections in the rules.
NAMI has joined a coalition of colleague national mental health substance abuse groups known as the “Parity Implementation Coalition” and will be submitting similar comments jointly with this coalition and separately. You can view these comments at:
NAMI National regrets the short turnaround time for these comments. As you can see, these comments are very detailed, running 26 pages in length, and involve interpretation of complex statutory and regulatory issues. NAMI was assisted in developing these comments by the Washington law firm Patton Boggs and it took a number of weeks of research and drafting to develop them.
NAMI State and Local Organizations Are Strongly Encouraged to Submit Comments
It is critical for NAMI organizations to join in and submit their own comments. It takes only a few seconds to submit comments on-line through the website included below. You can send a very brief comment endorsing separate comments submitted by the Parity Implementation Coalition and NAMI National. Doing so would serve as an endorsement of all of the comments and recommendations contained therein and be counted by the agencies as a full set of comments. The body of the comment you submit need only to state:
“On behalf of NAMI ________, I am writing to submit comments on the Interim Final Rules under the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008 and in doing so NAMI _________ endorses the separate comments submitted by the Parity Implementation Coalition and the National Alliance on Mental Illness”
You can then also include the full NAMI comments as a separate file attachment if you wish, although this is not required..
How to Submit Comments
1. Go to http://www.regulations.gov/search/Regs/home.html#submitComment?R=0900006480a8935c
2. Click submit comments
3. Fill out the required form
4. Cut and paste your comments in the box provided and/or attach them using the “attach a file” option
5. Click submit
If you have any questions, please do not hesitate to contact me at 888-999-6264, ext. 7940 or firstname.lastname@example.org
Thanks for your efforts to help achieve strong regulations enforcing the new federal parity law.
Please see below for sample comments.
Interim Parity Rules Sample Comments (PDF)