New Preventive Service Coverage Requirements for Employer Plans Target Behavioral Health

By D. Mark Wilson posted 02-04-2022 12:53


The Biden administration has announced important new wellbeing preventive service requirements, including behavioral health screenings for plan participants, for employer health care plans beginning in 2023. Employers will need to update their plans to make sure they provide first-dollar coverage for the new requirements.

Background: Under the ACA, non-grandfathered employer health plans must cover certain preventive services without cost sharing, including certain preventive care and screenings for infants, children, adolescents and women.

New wellbeing requirements: The updated guidelines for infants, children, and adolescents include new requirements for suicide and depression screening (for those aged 12 to 21); changes to behavioral, social, and emotional screening (for all ages); new risk assessments for cardiac arrest and death (for those aged 11 to 21); and a new risk assessment for hepatitis B (for all ages).

Employees may have trouble accessing behavioral health services. Inadequate access to mental health providers, particularly, for new patients makes it difficult for many to access needed care. According to HHS, 129.6 million Americans live in areas designated as Mental Health Professional Shortage Areas. There are 6,559 additional BH providers needed to fill these provider gaps. Provider shortages, in conjunction with limited in-network providers, make it difficult for patients to find affordable in-network providers. 

New requirements for women: The guidelines for women reflect updated recommendations for breastfeeding services and supplies; contraceptives; screening for HIV; counseling for sexually transmitted infections; and obesity prevention for women aged 40 to 60. The most notable changes include clarifications to the scope of breastfeeding equipment and supplies, as well as lactation consultations, and defining contraceptive follow-up care.

Outlook: Employers can expect additional preventive service requirements going forward. The U.S. Preventive Services Task Force currently has eight recommendations in their final stage review and the Association will update members when they come out.