TO: Commercial Health Insurers; Blue Cross Blue Shield of Massachusetts, Inc.; and Health Maintenance Organizations Offering or Renewing Insured Health Products in the Massachusetts
FROM: Daniel R. Judson, Commissioner of Insurance
DATE: November 3, 2015
RE: Using Standard Prior Authorization Forms when Reviewing Requests for Behavioral Health Services
The Division of Insurance (“Division”) issues this guidance to inform insured health carriers (“Carriers”) about the use of standard prior authorization forms when reviewing requests for behavioral health services. Pursuant to M.G.L. c. 176O, §25(c), the Division is mandated to implement health services prior authorization forms.
The Mass Collaborative, composed of representatives from insurance carriers, provider groups, and associations developed and submitted a series of standard prior authorization forms for use in reviewing behavioral health services. Based on the work of the members of the Collaborative, the group developed the following forms:
- Behavioral Health Disorders – Level of Care Request Form
- Repetitive Transcranial Magnetic Stimulation Request Form
- Psychological and Neuropsychological Assessment Supplemental Form
The Division held informational sessions on June 1 and June 10, 2015 to hear all thoughts about potential changes and received amended forms from the Mass Collaborative that were submitted to the Division to respond to comments raised in the information sessions. The amended forms, as included in the Appendix to this bulletin, are approved by the Division as the standard prior authorization forms for all behavioral health services covered under insured health plans. Carriers may no longer require the use of any other paper form other than the standard form, which it shall make available for use by all contracted providers.
By no later than 90 days after the issuance of the bulletin, the Division expects that all insured health plans shall take all necessary steps to amend their prior authorization processes to accept these standard prior authorization paper forms for behavioral health services that may be submitted by providers by mail, as an attachment to electronic mail, or by facsimile machine. The form will serve as sufficient information upon which the insured health plan should use in making its decisions for prior authorization of the requested service or procedure. For, providers who use existing forms for prior authorization, carriers will continue to accept these forms until six months after the issuance of this bulletin.
Six months after the issuance of this bulletin, the Division expects that all insured health plans will amend any electronic or internet-based systems used to collect prior authorization information, so that those systems will only ask questions as stated in the approved forms in a format and order substantially similar to the format of the approved format. Carriers wishing to modify the format or order from the standard form are required to submit screenshots of all such forms for the Division’s review before their use in the market. Data collected electronically by carriers for prior authorizations should be identical to the data collected on these paper forms.
The Division is aware that Carriers and providers may be at differing degrees of readiness for implementing standard prior authorization forms. Although many provider organizations may be ready to implement the new forms, it appears that other providers may not yet be prepared. As the paper forms become available, the Division strongly encourages Carriers to consider taking steps to work with provider organizations to educate contracted and other providers about the use of uniform prior authorization forms for behavioral health services. Carriers are encouraged to work with contracted providers to use the standard paper forms within 90 days and electronic form by no later than six months after the issuance of this bulletin..
If you have any questions about this Bulletin, please consider contacting Kevin Beagan at 617-521-7323 or Kevin.firstname.lastname@example.org.