Advancing Health Equity and Access to Psychological Services

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Request 1: Increase FY23 Appropriations and Authorizations for Psychology Workforce Development

Background:

The Graduate Psychology Education (GPE) Program is the nation’s primary federal program dedicated to the interprofessional education and training of doctoral-level health service psychologists. Established in 2002, GPE has the “two-for-one” benefit of supporting the interprofessional training of psychology graduate students and interns, while also expanding access to mental and behavioral health services for underserved populations in rural and urban communities. 

The Minority Fellowship Program (MFP) provides funding for training, career development and mentoring for mental and behavioral health professionals to work with individuals of color. The program focuses on training students, postdoctoral fellows and residents to be culturally and linguistically competent in addressing the needs of underserved areas. The program supports the trainees in psychology, nursing, social work, psychiatry, addiction counseling, professional counseling, and marriage and family therapy.  

Last reauthorized in 2016, both programs are expiring this year and need to be reauthorized by Congress.  

Sample Talking Points for States with GPE Grants: 

Please click on your state to view the grant abstracts for your GPE Programs. 

• Increased investments to support our nation’s psychological health and emotional well-being are needed now more than ever, as current data shows that Americans are experiencing a surge in COVID-related mental and behavioral health problems, including increases in anxiety, depression, and post-traumatic stress disorder. 
• Our state currently has [number] GPE grant(s) at [institution], which is supporting integrated training for psychology doctoral students and expanding access to mental and behavioral health services for underserved populations in [region of state]. 
• As you may know, there is a shortage of qualified mental health providers in our state, particularly in [rural/urban] areas. GPE funding is critical to increasing our state’s capacity to reduce health disparities and improve health care outcomes for high-need, underserved populations (e.g. older adults, children, individuals with chronic illness, veterans, victims of abuse, ethnic minority populations, and victims of natural disasters). 
• The GPE program is currently funded at $20 million. Increased funding for GPE to $30 million in FY23 would strengthen current efforts to expand the psychology workforce. 
• Last reauthorized in 2016 as part of the 21st Century Cures Act, GPE is expiring this year. Please include the reauthorization for GPE in any final mental health package. Draft reauthorization language can be found in the factsheet we provided.  

Sample Talking Points for States without GPE Grants: 

*Has previously had a GPE grant but does not have current funding. Please click here to see a full listing of previous GPE grants.  

• Increased investments to support our nation’s psychological health and emotional well-being are needed now more than ever, as current data shows that Americans are experiencing a surge in COVID-related mental and behavioral health problems, including increases in anxiety, depression, and post-traumatic stress disorder. 
• As you may know, there is a shortage of qualified mental health providers in our state, particularly in [rural/urban] areas. Funding for GPE provides a critical mechanism that could help increase our state’s capacity to reduce health disparities and improve health care outcomes for high-need, underserved populations (e.g. older adults, children, individuals with chronic illness, veterans, victims of abuse, ethnic minority populations, and victims of natural disasters). 
• Currently funded at $20 million, increased funding for GPE to $30 million in FY23 would strengthen current efforts to expand the psychology workforce by increasing opportunities for our state to apply for GPE funding. 
• Last reauthorized in 2016 as part of the 21st Century Cures Act, GPE is expiring this year. Please include the reauthorization for GPE in any final mental health package. Draft reauthorization language can be found in the factsheet we provided.  

Sample Talking Points for MFP:  

• The Minority Fellowship Program (MFP) aims to reduce health disparities and improve behavioral health care outcomes for racial and ethnic populations. 
• MFP supports training, mentoring, and career development for psychologists and other mental health professionals to provide culturally competent, mental and behavioral health services to diverse populations. 
• As you may know, there is a need to increase the number of culturally competent mental health professionals in our community. Culturally competent mental health professionals are important because [offer your own example or personal story]. 
• The Minority Fellowship Program is currently funded at $16.2 million. Increasing funding to $25 million in FY23 would allow more psychologists to work with diverse populations in what are often underserved areas. 
• Last authorized in 2016 as part of the 21st Century Cures Act, MFP is expiring this year. Please include the reauthorization for MFP in any final mental health package or stand alone bill. Draft reauthorization language is in the factsheet we provided. 
• These last two years especially have proven how necessary mental health care is in underserved populations. 

FAQs:  

What's the Difference Between GPE and MFP? 

GPE is administered by the Health Resources and Services Administration (HRSA) and provides grants to accredited psychology doctoral, internship, and postdoctoral training programs. The purpose of this program is to expand the capacity of clinical training programs to prepare doctoral-level psychologists to deliver mental and behavioral health care in settings that provide integrated primary and behavioral health services to underserved and/or rural populations. There are currently 49 grantees. 

MFP is administered by the Substance Abuse and Mental Health Services Administration (SAMHSA), and provides grants to professional associations that represent mental/behavioral health providers. APA is one of seven grantee organizations that administers the program. The overarching purpose of MFP is to improve behavioral health care outcomes for racial and ethnic populations. APA’s MFP seeks to accomplish this by increasing the number of racial/ethnic minority psychologists, as well as the number of psychologists with expertise in racial/ethnic minority behavioral health. Individuals also apply individually to be accepted to MFP programs. This differs from the GPE programs. 

A Congressional Office has asked us to fill out an FY23 Appropriations Request Form. Do I need to submit a form for both GPE and MFP? 

No. We are only submitting FY23 Appropriations Request forms for GPE for the March Advocacy Summit. There is a separate coalition that will submit all Appropriations Request forms for MFP.  

Who should submit our Appropriations Request Form for GPE? 

FACs should take the lead on submitting appropriations request forms for the delegation. For large states, the FAC may designate other members of the state delegation to help submit forms.  

Where can I find the information I need to fill out an Appropriations Request Form for GPE? 

Please click here. If you have any questions, please contact Alix Ginsberg, MPH 

How can I tell if APA has already filled out an Appropriations Request Form for GPE? 

Please click here. If you have any questions, please contact Alix Ginsberg, MPH 

What has MFP and GPE been funded at historically?

MFP was funded at the following levels for the last few years: FY18- $12.7 million; FY19-$13.2 million, FY20-$14.2 million, FY 21-$16.2 million, FY22-$16.2 million. Historical funding for GPE can be found at the bottom of this page. 

What level of funding was requested for GPE and MFP in the President's FY23 Budget Request? 

$25 million for GPE and $22.1 million for MFP

Request 2: Support Reimbursement for Psychology Interns and Residents in Medicare

Background:

• Despite their value and expertise in treating mental and behavioral health conditions, psychologists are not afforded the same training support that Medicare has long provided to primary care medical professionals. 
• Medicare generally does not cover services provided by medical trainees, but has carved out an exception to this policy for services provided by medical trainees in primary care medicine. 
• Although clinical psychology interns typically receive 1,000-2,000 hours of clinical experience prior to beginning their internship, services provided by trainees under the supervision of a licensed psychologist are not reimbursable under Medicare, nor are services provided by psychology residents engaged in post-doctoral degree training. 
• This lack of support for psychology interns and residents under the nation’s single largest health insurance program makes it difficult to support training programs, increase the workforce, and has trickle-down effects throughout the rest of the healthcare landscape, as other health insurance programs often look to Medicare coverage policies as a model for revising or updating their own coverage policies. 
• While CMS already allows several state Medicaid programs to cover services provided by psychology trainees, there is very little coverage of these services under private insurance plans.  

Sample Talking Points:

• Reimbursement for services provided by psychology interns and residents under Medicare would create more opportunities for trainees to gain experience working with this population, providing more incentive for psychologists to participate in Medicare once independently licensed.  
• Medicare coverage of trainee services would help support training programs and their growth and provide more equitable reimbursement of mental and behavioral health services. 
• Coverage of services provided by psychology trainees and residents would benefit both Medicare beneficiaries and the broader population covered by other forms of insurance in the long-term. 
• CMS already permits many state Medicaid programs to cover services provided by psychology interns and residents. However, this is currently a very patchwork solution, as different state Medicaid programs impose different limitations on coverage of these services. 
• Many primary care medical practitioners are seeking out models of integrating mental health services with primary care practices. Both the medical trainee and doctoral-level psychology trainee involved in integrated care programs should have equal degrees of support. 

FAQs: 

How many State Medicaid Programs have cover services provided by psychology interns and/or residents?  

With CMS’ approval, 24 state Medicaid programs provide at least some degree of coverage to psychology interns or post-docs for their services.  

Those states are AL, AK, AR, DE, GA, ID, IN, KY, MN, MO, NV, NM, OH, OK, OR, SC, TX, UT, VT, VA, WV, WI, and WY.  

However, there are a lot of variations and limitations amongst these coverage policies.  For example, some limit coverage to services provided by post-docs OR interns (sometimes referring to them under a different classification, i.e. “psychology associate”), while others limit coverage only to specific services or only to services provided in specific settings. 

My clinic does not use the terms “residents” or “interns” to refer to their psychology trainees. Should I relay this information during our meetings?  

These materials are intended to utilize terminology with which Congressional staff are most likely to be familiar. You are welcome to provide staff with a very brief and basic overview of training requirements for psychologists without getting bogged down in the nuances of different terminology. 

Does Medicare reimburse for supervised services provided by medical residents?  

Medicare generally does not allow reimbursement for services provided by medical trainees, with the exception of supervised services provided by medical residents in primary care.  

How might this change in Medicare impact other forms of insurance? 

Currently, very little coverage of services provided by psychology trainees is allowed through private plans. However, other health care insurers often look to Medicare coverage policies as a model in revising or updating their own policies. 

Has legislation been introduced on this? 
Legislation on this issue has not been introduced yet, and APA would be happy to work with any Member of Congress who would be interested in championing this issue.

Request 3: Co-sponsor the Parity Implementation Assistance Act and Authorize the Department of Labor to assess penalties for violation of parity law

Background:

• Despite passage of the Mental Health Parity and Addiction Equity Act in 2008 (MHPAEA), health plans are continuing to more tightly limit access to mental health and substance use services than for general medical care, taking advantage of the stigma still often associated with receiving behavioral health treatment.   
• MHPAEA prohibits the use of either quantitative treatment limits (such as the number of outpatient visits allowed per year) or nonquantitative treatment limits (NQTLs), such as prior authorization requirements, provider reimbursement rates, and provider network admission requirements. 
• Research shows parity has yet to be achieved.  A 2019 study by the consulting firm Milliman found that patients went out-of-network for behavioral health services 5 times as often as for general health care services, and reimbursement rates for primary care office visits were more than 20% higher than rates for behavioral health office visits, as compared to Medicare reimbursement rates.  The report also found that these disparities are growing. 
• Congress and President Trump enacted legislation in December, 2020 (the “Consolidated Appropriations Act”, or CAA) requiring health plans and health insurance issuers to carry out comparative analyses of the design and application of the nonquantitative limits they place on MH/SUD and general medical care, and make these analyses available to regulatory agencies on demand.   
• Health plans are not meeting the CAA requirements.  In January the Departments of Labor, Health and Human Services, and Treasury issued a report on MHPAEA enforcement efforts in 2021.  DOL issued 156 letters to health plans and health insurance issuers requesting their comparative analysis of nonquantitative treatment limits. None of the requested analyses contained sufficient information upon initial receipt, and all DOL reviews completed after receiving supplemental information resulted in an initial determination of non-compliance with MHPAEA. 
• DOL’s January report requests that Congress grant it the authority to assess civil monetary penalties for MHPAEA parity violations. Both the Obama and Trump administrations similarly recommended establishing this authority. Under current law, health plans and issuers face no financial penalty for violating the law besides having to pay for the services they inappropriately denied. 
• The Parity Implementation Assistance Act (H.R. 3753 / S. 1962) would support stronger state enforcement of MHPAEA by providing grant assistance for requesting and reviewing the comparative analyses that health plans are required to carry out of their use of nonquantitative treatment limits. 

Sample Talking Points:

• Health plans are continuing to violate the Mental Health Parity and Addiction Equity Act (MHPAEA) by designing and administering their plans in ways that disproportionately limit coverage of mental health and substance use services. 
• Congress passed legislation in 2020 requiring plans to compare and analyze what are known as “nonquantitative treatment limits” —such as reimbursement rates, preauthorization requirements, and network admission standards—to ensure that they do not disproportionately restrict access to behavioral healthcare. 
• The recent Department of Labor MHPAEA compliance report shows that plans are not complying with the law, and not conducting the required analyses. 
• The Department of Labor should be given the authority to assess civil monetary penalties on health plans and issuers for parity violations.  Without this authority, there is no meaningful incentive for plans to comply with MHPAEA. 
• Both the Obama and Trump administrations recommended establishing this authority for DOL, and the recent enforcement report does, as well. 
• Congress should also help state insurance regulators in enforcing MHPAEA for plans under their jurisdiction by enacting the Parity Implementation Assistance Act (H.R. 3753 / S. 1962).  This act would provide grants to states for requesting and reviewing the comparative analyses that health plans and issuers are required to carry out to ensure their compliance with MHPAEA. 

Additional Resources:

• 2022 MHPAEA Report to Congress: Realizing Parity, Reducing Stigma, and Raising Awareness: Increasing Access to Mental Health and Substance Use Disorder Coverage

Frequently Asked Questions

How can I prepare for the Summit?

All information for the Summit, including our legislative requests, fact sheets, agenda, and participant list can be found on this Summit action center. If you are not seeing the information you are looking for, please check back later - this page will be updated as we receive more information. 

If you are new to advocacy or would like a refresher, please watch APA’s Federal Advocacy for Psychology video.

Do I have to schedule my Hill visits for March 28?

No. Our partner, Soapbox Consulting, is handling all scheduling for legislative hill visits for March 28.

When will I get by schedule from Soapbox?

All Hill Day schedules will be emailed to you by Soapbox at the latest 12pm EDT on Thursday, March 24. On the “Meeting Roster” button next to each meeting, you can find the names and email addresses of your fellow advocates for each meeting so you can reach out in advance to introduce yourselves.

What if I can no longer make the March 28 Hill visits?

Please contact us at advocacy@apa.org as soon as possible so we may remove you from the congressional meeting schedule.

What platform is the Summit utilizing?

The Advocacy Summit will be hosted on Zoom. Please ensure that you have the most current Zoom version (5.6.3) by downloading the recent client for meetings here.

How can I attend the Summit?

All participants may join the Advocacy Summit via zoom at 11am EDT on March 27. A link will be provided shortly.

What is the program for the Summit?

The program for the Summit will be provided soon. Please check back here for updates; it will be linked to the top of this page when it is available.

How can I attend the Summit’s debriefing session?

All participants may join the Summit’s debriefing session on Monday, March 28, between 3:00pm and 5:00pm EDT via Zoom.