“Those [children] with military connections were more likely to report depressive symptoms and suicidal ideation….Findings emphasize the increased risk of mental health issues among youth with parents (and siblings) in the military.” Journal of Adolescent Health
Given that sobering commentary, I am thankful that the Department of Defense has finally proposed new mental health regulations, not only impacting children but all ten million beneficiaries in the Military Health System. In February, the Department of Defense published proposed regulations, accessible here:. While there is much to applaud in these changes, there is also a need to provide feedback on these proposed regulations (due 1 April).
The National Association for Children’s Behavioral Health (NACBH), part of our TRICARE for Kids Coalition, has been advocating for years to improve mental health treatment for military children and was the lead organization responding to these proposed regulations for our coalition [I highly recommend reviewing NACBH’s commentary (pages 11-14) in our coalition’s response to DOD’s evaluation of its military pediatric care to understand some of the most pressing issues military children face in accessing behavioral health treatment].
NACBH’s draft comments on these proposed regulations are accessible through this Drop Box Link. NACBH’s feedback is extensive. Below, I highlight three primary points:
- The Department of Defense is not subject to the Mental Health Parity and Addiction Equity Act (MHPAEA) of 2008 or the Patient Protection and Affordable Care Act (PPACA) (commonly referred to as Obamacare). NACBH notes that the proposed regulations should better conform to those pieces of legislation. Surely, our service members and their families are worth it.
- The proposed rule does not allow for intensive outpatient treatment or partial hospitalization programs for TRICARE beneficiaries who are younger than 13 years of age. Responding, Children’s Hospital of Philadelphia noted “Much like preschool programs have proven successful at improving a child’s academic performance throughout their academic career, it is also true that early mental health intervention and treatment provides significant health benefits throughout a child’s life span.” In their commentary, NACBH noted “There is no clinical evidence to support this arbitrary age restriction….We strongly urge the Department to remove the age restriction and the resulting risk that military families will have to choose between accepting an inadequate level of care or allowing their children to leave the family home for more intensive treatment than is needed.”
- While the proposed rule would remove the outdated and overly detailed standards and certification process that has kept providers from participating in TRICARE (residential treatment centers, in particular), DoD clearly intend to put new standards and some sort of certification in place instead, which could have the same effect.
These are significant changes, many of them much needed and long overdue, and many of them which need to be reconsidered and rewritten. The important thing is that you comment and have your voice heard. For those who wish to comment, you can do so here.
One observation for your consideration…for all the concern our society has about mental health, particularly suicide prevention, the lack of focus on these regulations is disappointing. Given the seriousness of this issue, I would have expected many, many more comments to date. Hopefully, your help in spreading the word about these changes will make a difference.
Our military families are worth it.
About the Author: Jeremy Hilton is a Navy veteran, Air Force spouse, author, and advocate. He helped repeal the COLA cuts in the 2013 BCA as a #KeepYourPromise cofounder and is currently working to reform military pediatric healthcare as a “TRICARE for Kids” Champion. Jeremy has written for Time, Huffington Post, Military Spouse magazine, USAA, and Exceptional Parent magazine.