Comment on CMS-2026-2081-0001
InseparableSupportAdvocacy
Summary: A coalition of mental health and substance use disorder organizations argues that the current Essential Health Benefits (EHB) framework is outdated because it is anchored to pre-parity employer plan designs. They urge CMS to update the EHB to include evidence-based behavioral health services, arguing that such coverage improves affordability by reducing total costs of care and correcting statutory imbalances.
On behalf of Inseparable and the undersigned national mental health and substance use disorder organizations, we submit the attached comments in response to CMS-9874-NC. Our comments address Topics 1, 3, 4, 5, 6, and 7, explaining how the timing of the EHB benchmark framework's rollout relative to federal parity implementation left MH/SUD coverage anchored to pre-parity plan designs, and how expanding coverage of evidence-based MH/SUD services would improve affordability by reducing total cost of care. Please see the attached PDF for our full comments.