CSAM Comments on Prenotice Parity Regulations

On November 1st, the California Society of Addiction Medicine (CSAM) sent written comments to the California Department of Insurance in response to their prenotice public discussion for the implementation of SB 855. CSAM expressed support for the proposed parity regulations, while identifying areas of improvement for the final version.

In the letter, CSAM praised the proposed regulations for protecting coverage parity for people with substance use disorder (SUD). Specifically, CSAM identified language requiring that non-profit professional association criteria be used for medical necessity determinations as an improvement. However, the proposed regulations omitted language requiring coverage for all levels of care. CSAM noted the importance of requiring that all levels of care are covered in the final regulation. Additionally, CSAM urged that the Department consider adding enhanced enforcement penalties to deter parity violations, especially penalties targeting repeated offenders. 

Read the letter here.