A Review of Behavioral Health Benefits in Newly Reformed Individual MarketplacesServices and Drug Coverage Sponsored by Produced by Section I A comparison of behavioral and physical health benefits as well as provider networks in Bronze and Silver plans in five states. Section II An analysis of drug coverage, utilization management, and costsharing for 25 products in nine states. Speaker: JANE HORVATH September 11, 2014 INTRODUCTION Mental Health America and Takeda-Lundbeck commissioned comparative research of Bronze and Silver level individual market Exchange plans in nine MHA- priority states (AZ, CA, CO, IL, MD, MT, NJ, NY, TX). SECTION I: A comparative review of services, cost-sharing, and provider networks for behavioral and physical health in individual market Exchange plans in five of the nine priority states. SECTION II: A market scan of plan formularies to assess coverage, tier placement, utilization management, and cost-sharing trends for 25 antidepressants and bipolar therapies in the individual market Exchange of the nine priority states. 2 I SECTION BEHAVIORAL HEALTH BENEFITS AND PROVIDER NETWORKS SECTION I: STUDY QUESTIONS BEHAVIORAL HEALTH BENEFIT AND PROVIDER COMPARISONS • Cost-sharing • Office visits, inpatient, outpatient? • In-network, Out-of-network? • Is BH included in OOP Maximum? • Deductible • Separate BH? • Any services excluded? • Access • BH provider in-network? • Prior authorization or referrals required for access? 4 SECTION I: METHODOLOGY • Compared and contrasted the behavioral health and physical health benefits in two Silver and two Bronze metal level plans in the individual market in the Exchanges of the most populous regions of five MHA –priority states: AZ, IL, MT, NJ, TX.* • Used publicly available documents – plan summary of benefits and coverage, plan provider search functions. • When available, only used data on providers listed as accepting new patients but four plans (20%) did not have this public capacity • Assumed that unless otherwise specified, an BH provider is considered a ‘specialist” in each plan and patient access requires specialist-level costsharing • Selected oncologists as comparator group to psychiatrists after consultation with MHA. • There may be duplication in provider counts because some plan search functions include each provider location as a distinct, countable provider. BEHAVIORAL HEALTH BENEFIT AND PROVIDER COMPARISONS *These are all Federally-Facilitated Exchanges which keep plan information public outside of the open enrollment period. State exchanges had incomplete data available for this analysis and thus were not included in this Section. 5 Findings: BEHAVIORAL HEALTH SERVICE ATTRIBUTES No clear distinctions in services/cost sharing between metal levels or states. BEHAVIORAL HEALTH BENEFIT AND PROVIDER COMPARISONS All plans appear to technically comply with the Mental Health Parity and Addiction Equity Act • All plans have equal or comparable cost sharing and utilization management requirements for physical, mental and behavioral health. • There were no explicit service restrictions on behavioral health services in any plan. • Behavioral health cost sharing included in the out of pocket maximum of all plans. Service Coverage Highlights: • 8 plans (40%) require prior authorization or referral for specialist care • 7 plans (35%) have no cost sharing for both inpatient in-network behavioral health and substance abuse services 6 Findings: BEHAVIORAL HEALTH PROVIDER NETWORKS This research is not sufficient to evaluate network adequacy. All these plans meet federal requirements for adequacy. BEHAVIORAL HEALTH BENEFIT AND PROVIDER COMPARISONS Nearly all plans included coverage for nonphysician providers, such as licensed clinical social workers or licensed mental health counselors. Depending on the plan behavioral health providers may or may not include psychiatrists. Seven plans have over 350 behavioral health providers in network, while nine plans have over 100 mental health providers in-network. Six plans have fewer than 10 behavioral health providers in-network. Thirteen plans (65%) have a greater number of psychiatrists than oncologists in-network. Caveats: • All plan provider network information may not be up to date; • Some plans do not provide information on which providers accept new patients, and • This research does not include demographic analysis that might better answer a question of network adequacy. 7 With all the caveats about data quality and sample size; Summary: BEHAVIORAL HEALTH PROVIDER NETWORKS Out of pocket costs appear to be equal to physical health. • Issues • Is there behavioral health primary care? • Are there clinical preventive services that could be considered for first dollar coverage? Robust networks are not a guarantee of access. • Did not study demographics of access: time, distance, or income. BEHAVIORAL HEALTH BENEFIT AND PROVIDER COMPARISONS 8 COMPARING BEHAVIORAL AND PHYSICAL HEALTH BENEFITS AND PROVIDER NETWORKS Inpatient, In-Network Outpatient, Out-ofState Plan Humana Connect 6300/6300 Bronze Arizona BCBS Everyday Health Alliance 6000 Bronze Humana Connect Silver BCBS Everyday Health Alliance 4000 Silver Blue PPO Bronze 006 Illinois Humana Connect Bronze 6300/6300 Blue Choice Silver PPO 003 Humana Connect Silver 4600/6300 Access Care Bronze SmartHealth Value Bronze 3000 Montana PacificSource: SmartHealth Value Silver 3000 Connected Care Silver: Montana Health Cooperative New Jersey AmeriHealth NJ Tier 1 Advantage – Bronze EPO Horizon Advantage EPO Bronze Horizon Advance EPO Silver AmeriHealth NJ Tier 1 Advantage – Silver EPO H.S.A. Blue Advantage Bronze HMO 005 Blue Advantage Bronze HMO 006 Texas Molina Marketplace Silver Plan Blue Advantage Silver HMO 003 BEHAVIORAL HEALTH BENEFIT AND PROVIDER COMPARISONS Cost-Sharing Behavioral Health vs. Physical Health Network Cost-Sharing Behavioral Health vs. Physical Health Psychiatrists vs. Oncologists Overall Number of Behavioral Health Providers* = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = < > > > > > > < < > > < < > > < > > < > 592 X = = X = = = = 7 589 7 0 1346 0 1346 5 189 190 4 22 45 45 22 399 399 21 399 > MORE PSYCHIATRISTS THAN ONCOLOGISTS = BEHAVIORAL HEALTH AND PHYSICAL HEALTH COST-SHARING IS THE SAME < LESS PSYCHIATRISTS THAN ONCOLOGISTS X NO INFORMATION * THESE NUMBERS DO NOT TAKE INTO ACCOUNT PROVIDERS LISTED AT MULTIPLE LOCATIONS. MAY OR MAY NOT INCLUDE PSYCHIATRISTS. MEDICAL NECESSITY DEFINITIONS All plan summary of benefits and coverage refer to the ACA Uniform Glossary for the definition of “medical necessity” Medical Necessity“Health care services or supplies needed to prevent, diagnose, or treat an illness, injury, condition, disease, or its symptoms and that meet accepted standards of medicine.” -ACA Uniform Glossary • Developed by HHS and DoL • Actual interpretation will likely develop and be refined over time with federal guidance, lawsuits, etc. • Only two plans in this study specified the need for a covered service to be medically necessary • Both are Illinois plans and the service in question was primary care BEHAVIORAL HEALTH BENEFIT AND PROVIDER COMPARISONS 10 In two states, Texas and Illinois, Silver plans had higher cost sharing than Bronze plans—for both inpatient and outpatient coverage. Findings: BRONZE VERSUS SILVER PLANS From a behavioral health/substance abuse standpoint, Bronze vs. Silver AV level was not indicative of less cost sharing or a stronger provider network. Five plans require no cost sharing for behavioral health/substance abuse outpatient services. • Four Bronze, one Silver. Seven plans require no cost sharing for behavioral health/substance abuse inpatient services. • Four Bronze, three Silver. Behavioral health provider network participation seems more highly correlated to carrier/plan sponsor than metal level. Network participation information captured in this analysis reflects all the shortcomings of the carrier/plan public data. BEHAVIORAL HEALTH BENEFIT AND PROVIDER COMPARISONS 11 II SECTION FORMULARY REVIEW OF BEHAVIORAL HEALTH THERAPY COVERAGE • Reviewed 25 behavioral health drug treatment therapies for coverage in plans sold on the individual market Exchanges of nine states using publicly available summaries of benefits and coverage and drug formularies. • SECTION II: METHODOLOGY • Where coverage varied based on dosage form or strength, Breakaway captured information on the form/strength with the least access restrictions. • States Reviewed Arizona California Colorado Illinois Maryland Montana New Jersey New York Texas FORMULARY REVIEW OF BEHAVIORAL HEALTH THERAPIES • Plans included were selected on the basis of largest enrollment or plans in the most populous region of a state. All averages are simply mathematical averages, not weighted. 72 plans (36 Bronze, 36 Silver) • 4 Bronze, 4 Silver per State • 2 HMOs, 2 PPOs per State/per metal level where possible (EPO and POS used in absence) Products Abilify Brintellix Celexa Clozaril Cymbalta Efexor Fetzima Geodon Invega Latuda Lexapro Paxil Pristiq Prozac Risperdal Saphris Savella Seroquel Viibryd Zoloft 13 Zyprexa Depakote Lamictal Lithane Tegetrol Average Coverage Rates of All 25 Behavioral Health Therapies Within Each State 100% AVERAGE COVERAGE RATES WITHIN STATES 90% 95% 87% 84% 80% 70% 62% 83% 79% 62% 60% 50% The average frequency of coverage for 25 products among 8 plans in each the 9 states. 40% All Exchange plans are required by law to have an appeals process to request a drug not listed on a plan’s preferred drug list. 20% 30% 10% 0% N= 8 plans/state FORMULARY REVIEW OF BEHAVIORAL HEALTH THERAPIES 14 75% 79% Average Coverage Rates Across States by Metal Tier Percent of Drug Lists/Formularies AVERAGE COVERAGE RATES WITHIN STATES BY METAL LEVEL 100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% 96% 93% 90% 84% 84% 84% 64% 60% 84% 81% 88% 82% 76% 61% 62% Arizona California Colorado 85% 73% 62% Illinois Bronze 15 Montana Maryland State Silver New Jersey New York Texas Includes all drugs in all plans across all 9 states. Average Coverage Rates of Branded and Generic Products Percent of Drug Lists/Formularies AVERAGE COVERAGE RATES OF BRANDED VS. GENERIC THERAPIES 100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% 50% 94% 50% 6% Branded Generic No 16 Yes BRANDED COVERAGE FINDINGS 9 branded products Abilify Brintellix Fetzima Invega Latuda Pristiq Saphris Savella Viibryd • All drugs covered in each Metal level by at least one plan • Illinois and Texas • No Difference in Coverage Count Among Metal Levels • Illinois, Texas, Colorado, Montana, New Jersey • Greater Product Coverage in Bronze v Silver Plans • Texas, California • Greater Product Coverage in Silver v Bronze Plans • Arizona, Maryland, New York • No state had no coverage of brands in any metal level • Brintellix frequently excluded on one or both levels • Pristiq only excluded in Montana 17 Tiering Clusters of All Covered Products by Plan Type 100% TIERING “CLUSTERS” BY PLAN TYPE Percent of Drug Lists/Formularies 90% 80% 70% 65% 63% 61% 60% 50% 48% 40% 28% 30% 23% 20% Count of covered products by tier across all 72 plans and across all 9 states. 11% 13% 8% 10% 22% 20% 9% 6% 9% 6% 0% 2% 3% 0% 0% Tier 1 Tier 2 HMO • Tier 3 PPO EPO Tier 4 • Plan Does Not Specify POS Drugs with high rates of coverage are placed on Tier 1 • Celexa, Lithane, Risperdal, Lexapro Infrequently covered drugs, when covered, are commonly on Tier 3 • Viibryd, Brintellix, Fetzima, Saphris FORMULARY REVIEW OF BEHAVIORAL HEALTH THERAPIES 1% 18 Tiering Averages of All Covered Products by Metal Level TIERING “CLUSTERS” BY METAL LEVEL Count of covered products across all 72 plans across all 9 states Percent of Drug Lists/Formularies 100% 90% 80% 70% 60% 61% 53% 50% 40% 28% 23% 30% 20% 12% 9% 10% 1% 0% Tier 1 Tier 2 Tier 3 Bronze • Tier 4 • Plan Does Not Specify Silver Drugs with high rates of coverage are placed on Tier 1 • Celexa, Lithane, Risperdal, Lexapro Infrequently covered drugs, when covered, are commonly on Tier 3 • Viibryd, Brintellix, Fetzima, Saphris FORMULARY REVIEW OF BEHAVIORAL HEALTH THERAPIES 8% 4% 2% 19 Tiering Clusters of All Covered Products By State 100% 90% Count of covered products across all 72 plans across all 9 states 80% 77% 70% Percent of Drug Lists/Formularies TIERING “CLUSTERS” BY STATE 70% 60% 63% 59% 59% 59% 57% 53% 51% 50% 40% 29% 28% 30% 26% 27% 27% 21% 15% 20% 11% 12% 10% 14% 12% 10% 9% 7% 6% 23% 19% 2% 1% 1% 0% 0% 0% 5% 2% 12% 12% 9% 9% 0% 1% 0% 0% 0% 0%0% 0% Tier 1 Tier 2 Tier 3 Tier 4 Tier Arizona Maryland FORMULARY REVIEW OF BEHAVIORAL HEALTH THERAPIES California New Jersey 20 Colorado New York Illinois Texas Plan Does Not Specify Montana OVERVIEW OF FINDINGS FINDINGS COST SHARING • Use of prescription-only deductibles in 4 states: AZ, CA, IL, MD • Lowest in CA ($250) • Varies significantly by metal level • Little variation in copays and coinsurance by metal level • High rates of utilization management, especially quantity limits FORMULARY REVIEW OF BEHAVIORAL HEALTH THERAPIES 21 Average Rx-Only Deductible Across States $1,400 $1,167 AVERAGE PRESCRIPTIONONLY DEDUCTIBLES BY STATE Average Rx Deductible $1,200 $1,000 $1,000 $800 $778 $730 $600 $400 $250 $200 $- Arizona California Illinois Maryland Overall State FORMULARY REVIEW OF BEHAVIORAL HEALTH THERAPIES • Only 4 states analyzed used a prescription-only deductible, with CA’s being significantly lower than the rest. • The other states in the study used combined (medical+prescription) deductibles, which were not captured in this analysis. 22 Average Rx-Only Deductible by Metal Level $1,600 $1,400 Average Rx Deductible AVERAGE PRESCRIPTIONONLY DEDUCTIBLES BY METAL LEVEL $1,500 $1,200 $1,000 $698 $800 $778 $600 $400 $200 $- Bronze Silver Overall Metal Level • Among the 4 states using a prescriptiononly deductible FORMULARY REVIEW OF BEHAVIORAL HEALTH THERAPIES 23 COST-SHARING IN PLANS WHERE RX EXEMPT FROM ANY DEDUCTIBLE BY METAL LEVEL $40 Dollars Average copays by metal level across all states and among all plans that exempt Rx from any deductible. Average Copay in Plans Where Rx Exempt From Combined Deductible $28 $30 Bronze Silver $30 $20 $10 $- Metal Level Only includes plans that specify a copay amount. FORMULARY REVIEW OF BEHAVIORAL HEALTH THERAPIES 24 Average Copay Before Deductible is Met $35 $30 $30 $25 Dollars AVERAGE COSTSHARING WHEN DRUGS APPLY TO DEDUCTIBLE BY METAL LEVEL $17 $20 $15 $10 $5 $- Bronze Average cost-sharing among all plans and across all states Metal Level Only includes plans that specified a costsharing value greater than $0 or 0% Average Coinsurance Before Deductible is Met Percent Top chart is average copay before any deductible is met by metal level Lower chart is average coinsurance before any deductible is met by metal level Silver 100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% 100% 100% Bronze Silver Metal Level FORMULARY REVIEW OF BEHAVIORAL HEALTH THERAPIES 25 AVERAGE COSTSHARING WHEN DRUGS APPLY TO DEDUCTIBLE BY METAL LEVEL Dollars Average Copay After Deductible is Met $16 $14 $12 $10 $8 $6 $4 $2 $- $14 $3 Bronze Average cost-sharing among all plans and across all states Silver Metal Level Only includes plans that specified a cost-sharing value Average Coinsurance After Deductible is Met Top chart is average copay after any deductible is met by metal level 100% Lower chart is average coinsurance after any deductible is met by metal level Percent 80% 60% 40% 23% 11% 20% 0% Bronze Silver Metal Level FORMULARY REVIEW OF BEHAVIORAL HEALTH THERAPIES 26 Utilization Management Rate Among HMO Plans AVERAGE UTILIZATION MANAGEMENT BY PLAN TYPE Percent of Drug Lists/Formularies 100% 100% 100% 90% 80% 81% 77% 76% 81% 81% 81% 80% 70% 60% 57% 52% 50% 67% 62% 54% 41% 35% 40% 31% 31% 36% 31% 31% 30% 20% 10% 0% 0% 0% 0% 0% Product Branded Key takeaway: Utilization Management Rate Among PPO Plans 100% 100% Percent of Drug Lists/Formularies Slightly higher application of UM in HMO plans with a similar, though less frequent, pattern across drugs among PPO plans 94% 90% 80% 94% 89% 86% 78% 69% 70% 56% 60% 50% 43% 38% 40% 30% 29% 26% 4% 13% 8% 0% 13% 8% 0% 0% 0% FORMULARY REVIEW OF BEHAVIORAL HEALTH THERAPIES 38% 29% 21% 20% 10% 94% 23 Branded Product Generic 4% Rates of Utilization Management Type of UM By State 100% AVERAGE RATE OF UTILIZATION MANAGEMENT BY STATE AND TYPE OF UM Key takeaways: Quantity limits most common UM approach Step therapy is a significant UM approach Percent of Drug Lists/Formularies 90% 80% 70% 60% 52% 50% 50% 42% 40% 37% 37% 36% 30% 20% 10% 20% 16% 15% 10% 13% 10% 1% 1% 21% 18% 17% 12% 3% 3% 8% 3% 5% 4% 0% 0% State Quantity Limits FORMULARY REVIEW OF BEHAVIORAL HEALTH THERAPIES 28 16% Step Therapy Prior Authorization 0% Few differences in cost-sharing between Bronze and Silver plans KEY FORMULARY TAKEAWAYS Branded products covered less often and placed on Tier 3 when covered High utilization management rates, particularly for branded drugs Quantity limits used heavily in most states No readily available information to indicate disparate treatment of behavioural health/substance abuse services from physical health. 29 A Review of Behavioral Health Benefits in Newly Reformed Individual MarketplacesServices and Drug Coverage Sponsored by Produced by Speaker: JANE HORVATH September 11, 2014 A P P E N D I X COVERAGE RATES OF EACH DRUG BY STATE Coverage Rate Among 8 Colorado Plans by Metal Level 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% Percent of Drug Lists/Formularies 90% 80% 75% 75% 75% 75% 75% 62% 61% 70% 60% 50% 50% 40% 30% 20% 10% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Product Branded FORMULARY REVIEW OF BEHAVIORAL HEALTH THERAPIES Bronze 32 Silver 0% 0% Coverage Rate Among 8 Illinois Plans by Metal Level 100% 100% 100% 100%100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 93% Percent of Drug Lists/Formularies 90% 80% 75% 70% 60% 50% 50% 50% 40% 30% 96% 25% 25% 20% 10% 0% Product Branded FORMULARY REVIEW OF BEHAVIORAL HEALTH THERAPIES Bronze 33 Silver Coverage Rate Among All 8 New Jersey Plans by Metal Level 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 90% Percent of Drug Lists/Formularies 82% 80% 75% 75% 75% 75% 75% 75% 70% 60% 50% 50% 50% 50% 50% 50% 50% 40% 30% 20% 10% 0% 0% 0% 0% 0% Product Branded FORMULARY REVIEW OF BEHAVIORAL HEALTH THERAPIES Bronze 34 Silver 0% 0% 76%
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