The
Massachusetts Medical Society wishes to be recorded in support of
SB1093/HB1070, An Act to further define medical necessity determinations. The
Medical Society believes all patients should have ready access to appropriate
mental and behavioral health care. This bill supports that goal by ensuring
that determinations of medical necessity in mental health care will be made by
physicians in consultation with patients. Medical necessity is, as the name
suggests, a medical determination, which ought to be made through the shared
decision making model of clinician-patient collaboration, and without intrusion
by the health insurance companies.
The
Medical Society’s policy particularly emphasizes the importance of ensuring
access to mental health services given the stigma and burdens often associated
with seeking mental health care. Our policy states that “all insurers offering
mental health services [ought to] adhere to the following principles”:
“Maintain an acute awareness that patients
often feel stigma in seeking mental health services. Because of this, there
must be…active efforts to insure patient dignity and elimination of potential
barriers to service, such as voice mail mazes, unnecessary intake questions and
difficulty accessing providers…Eliminate burdensome, redundant, and not
clinically useful paperwork.”
This
bill supports insurer compliance with the above guidelines; therefore, the
Medical Society views this legislation as important advocacy for this
vulnerable patient population.
We
wish to state, however, that this bill ought to be expanded to apply to all
health services, and not only to mental health, for reasons of both parity and
justice. Our policy states that insurers offering mental health services ought
to adhere to the principle of parity, such that “review and authorization
processes should be no different than those for physical illness.” We therefore
urge that, in accordance with that principle and with our points above, medical
necessity across both physical and mental health care services ought to be
determined exclusively by physicians, in consultation with patients.
