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The Biden-Harris Parity Rule & The Current State of In-Network Mental Healthcare - How Far Do We Still Need to Go?

A quick look at how robust current provider networks are for mental healthcare using private insurance's machine readable files.

Anav Sharma



On July 25th, the Biden-Harris office took action to expand access to mental health-care. Here’s some text from the official White House Fact Sheet on what private insurance needs to now look at:

One clear ask for health plans coming out of the regulation is comparing how accessible mental healthcare services are vs. other common types of care (e.g., primary care) to achieve parity. 

To answer broad questions like these, the payer Machine Readable Files (MRFs) from the Transparency in Coverage act (TiC, for short) are often the best tool available to get fast answers directly from the source. The TiC act requires MRF files contain the fee schedule for every credentialed NPI / EIN in a health plan so you can use the data to effectively analyze network size, scope, and composition (in addition to rates, prices).

In the context of the Biden-Harris rule, we can use the MRFs to analyze the following components of what drives access to mental healthcare, including but not limited to

  1. Comparing how many mental healthcare providers exist in-network vs. primary care (or some other specialty)
  1. Comparing how expensive it is to receive mental health-care vs. other types of care

Since we have already blogged about rates and cost of care a ton (see: here, here, and here), today we will focus on piece 1 above: provider supply. 

For example, if we wanted to ask how many mental healthcare providers does Aetna have in its Open Access Managed Choice PPO? We would need to:

  1. Assess what kind of provider each NPI / EIN is in Aetna’s MRF. To do this, Serif enhances the data by joining in the NUCC taxonomy for each provider using our proprietary provider directory. Now, we can see who is a doctor, nurse practitioner, or surgeon, etc.
  1. Classify / tag which providers fall under “mental healthcare” – to be comprehensive, let’s say we want to include all of the following: psychologists, marriage & family therapists, counselors, social workers, psychiatrists, and mental health registered nurses / nurse specialists. Basically, anyone trained and licensed on how to run a therapy session. 
  1. Count the unique number of individual NPIs to come up with an estimate. In this case for Aetna, we see about ~200K providers nation-wide (which is in the realm of reason based on secondary estimates from industry associations). 
  1. Repeat steps (1)-(3)  for primary care and now you have a rough way to assess parity between medical care and mental healthcare nationally. 

Now, let’s say you want to see which states are at parity for mental healthcare, or have a shortage. Luckily, another enhancement Serif adds to the source MRF data is supplying geolocation for each individual NPI to facilitate these analyses. 

After converting the counts to per-capita figures, you can plot the ratio of number of primary care providers vs. therapists in a heat-map like this across the US: the darker the shade – the more mental healthcare supply is necessary to catch up to primary care. 

For Aetna specifically, the states furthest away from parity (i.e., needing the most supply of mental healthcare vs. number of primary care options) are: 

  • Alabama – requires roughly ~3.5x the number of mental healthcare providers
  • Minnesota – requires roughly ~3x the number of mental healthcare providers
  • Mississippi – requires roughly ~2x the number of mental healthcare providers
  • South Carolina – requires roughly ~2x the number of mental healthcare providers
  • Tennessee – requires roughly ~2x the number of mental healthcare providers

Of course, there are many nuances to tease out here, such as: 

  • How do we factor in telehealth? Even if an NPI does not have an address in a given state, they still may be licensed to practice via an online visit. Including this could significantly increase the supply of mental healthcare. 
  • How has this trended over time? If the number of mental health providers is growing month over month faster than primary care, Aetna may be on pace to reach parity soon in the above-mentioned areas.

Fortunately, with a partner like Serif, we have the knowledge and capabilities to dive into these questions and help you build answers. If you are interested in seeing what else is possible with the data, feel free to reach out.

Note: The analysis presented here should be taken as directional and illustrative. The numbers discussed are highly sensitive to the completeness and accuracy of the contents of Aetna MRF postings, and different assumptions may yield different findings. This analysis utilized Aetna’s Open Access Managed Choice TiC posting from August 2023.