First Focus submitted comments on the proposed CMS rule concerning Medicaid Managed Care Organizations (MMCOs), CHIP, Alternative Benefit Plans, and mental health parity requirements. Long awaited, these proposed rules will help protect the children and adolescents who suffer from mental health disorders, substance abuse disorders, and other behavioral health challenges. Our comments focus on issues related to children and adolescents particularly those children who receive SSI or who reside in therapeutic foster care; the development of actuarially sound rates; the presumption that EPSDT coverage provides parity; the length of time for compliance with the rule; and the non-quantitative treatment limits.
