Constant Contact



January 31, 2018

Senator Karen Spilka Senator James Welch Senator Paul Feeney

24 Beacon Street 24 Beacon Street 24 Beacon Street

Room 212 Room 413-B Room 507

Boston, MA 02108 Boston, MA 02108 Boston, MA 02108

Oversight hearing relative to the Medical and Behavioral Health Procurement for employee health insurance coverage by the Group Insurance Commission

Dear Chairs Spilka, Welch, and Feeney:

The National Association of Social Workers - MA Chapter has a robust membership of 6,500 social workers that help individuals in a variety of settings. The majority of our members are clinicians who accept many types of insurance, both public and private. When the Group Insurance Commission announced their decision to cut a number of popular insurance plans, affecting 200,000 workers, we were worried about the inadvertent consequences this would have for clients who utilize behavioral health services.

Our first and foremost concern is in relation to workers being able to keep their current providers, an important part of continuity of care, which was inaccurately reported as easy to do. This can be a difficult transition to make due to various factors:

• The new insurance plan may not offer out-of-network options (Ex. Neighborhood Health Plan, or “NHP,” has none). This means that a worker would not be able to continue to see the same provider unless that provider joins a new insurance panel.

• Providers may face barriers in joining the new insurance panel. Many of our members have struggled to join new panels, typically because these panels are closed, stating they have an adequate number of clinicians serving their insured members. It has already been established that updating provider directories has been a challenge, resulting in inaccurate networks that may list full or inactive clinicians (often referred to as ghost networks). By closing their panels, this decreases access to mental health services for workers and eliminates possibility to continue with their current provider.

• Increase in premiums and/or co-pays. Even if out-of-network benefits exist (as it does with Unicare and Beacon Health Options), the cost can be up to three times than that of seeing an in-network provider. For low paid workers, these added costs can be especially prohibitive and may deter a client from seeking care.

In addition to a financial burden and taking the time to fill out cumbersome paperwork, there is a great concern about continuity of care and the importance of the therapeutic relationship. Continuity of care is vital to a worker’s productivity because it allows an individual to stay in the community/work by meeting with their trusted provider twice a month for a low co-pay (average $20 a session). By reducing or eliminating the ability to continue this therapeutic relationship, it increases the risk of an individual ending behavioral health services, leading to more mental health days and less time at work and in the community.

If these changes are to be made, we believe that GIC should ensure continuity of care so that employees can retain their current behavioral health providers by granting:

• In-network copays for providers with whom the insured has a relationship

• No deductibles for out-of-network care

• Single-case agreements should be available to insureds who have received treatment from providers within the past 6 months – at in-network co-pay rates.

Lastly, with the Commonwealth’s rightly-placed focus and attention on the opioid crisis and the prevention of over-reliance on opioid medication, we suggest that GIC plans cover proven alternative means for controlling pain. Currently, evidence-based services like acupuncture, chiropractic services, mindfulness/meditation programs, and massage are not covered under the majority of GIC plans. We believe that these services should be covered as it assists with the Commonwealth’s goals listed above.

We welcome you to contact us for any further questions as we are dedicated to ensuring that all members of the Commonwealth have access to comprehensive and affordable behavioral health services.

Sincerely,

Sophie Hansen, LCSW

Political Director

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