This week, CSAP joined other organizations in submitting formal comments on the Department of Managed Health Care’s (DMHC) proposed regulations to implement Senate Bill 855. You may view the comment letter here. In the back and forth leading up to finalization of the letter, DMHC staff were convinced to take a second look at previously closed cases to determine if further assessment of complaints is necessary. Also, in the case of Spravato, this coalition emphasized the need for coordination between referring/transferring providers since many health plans routinely identify providers available for consultation without regard to whether they are REMS-certified or even available to initiate treatment (rather than merely provide a consult) by a certain date. Lastly, the coalition stressed the issue of health plans identifying providers as “in-network” when in fact they are not. Very specifically, SYASL advocates ensured that DMHC staff understand physicians and practices have recently been exposed to immense financial risk due to delays and denials by the health plans, and that new regulations need to remedy this as much as possible.

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