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NASW Comments on Essential Health Benefits

By Carrie Dorn, MPA, LMSW Senior Practice Associate, Health


In December 2022, the Centers for Medicare & Medicaid Services (CMS) issued a request for information regarding the Essential Health Benefits covered under the Patient Protection and Affordable Care Act (ACA). The Essential Health Benefits (EHB) include 10 categories of services that health insurance plans must cover under the ACA. NASW has long supported the ACA and efforts to enhance health and well-being through the law. NASW submitted comments on a range of topics including:

  • Barriers to mental health and substance use disorder services
    • Meet increased demand for services and address workforce shortages
    • Expand racial diversity in workforce
  • Broaden access to telehealth services
    • Increase telehealth usage
    • Address inequities in telehealth access
  • Advance health equity and address underserved populations
    • Document health-related social needs
    • Enhance EHB coverage to reduce health disparities
  • Coverage of mental and behavioral health services
    • Address behavioral health needs in underserved communities
    • Expand maternal mental health
  • Coverage of emergency behavioral health services
    • Improve mobile crisis care and stabilization services
  • Habilitation Services
    • Strengthen covered benefits
  • Pediatric services
    • Enhance comprehensive benefits for children and youth
  • Substitution of EHB
    • Use flexibilities to maximize consumer access to health services

The full text of NASW’s comment letter is available here.