Behavioral Healthcare

Beyond ACA Limitations: Building a Continuum of Behavioral Health Care

When fragmented mental health care systems leave employees struggling, integrated care models offer a way to prioritize wellbeing without losing sight of ACA compliance.

Written by
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Sean Bell
General Manager of New Venture
Clinically reviewed by
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    Every day, employees face a tough choice: navigate fragmented mental health care systems or endure their struggles in silence. This disjointed model impacts individual lives, workplace productivity, healthcare costs, and organizational wellbeing.

    Despite one in five Americans experiencing mental health challenges, less than half receive the care they need. We’re in the midst of an untreated behavioral health care crisis that demands immediate action.

    However, there is a better path forward. Integrating Employee Assistance Programs (EAPs) with health plans can create seamless, ACA-compliant care experiences. Prioritizing continuity of care means bridging the gap between “excepted benefits” and medical coverage—so people aren’t forced to restart their mental health care journey when EAP benefits run out.   

    Having spent 25 years in the healthcare industry and leading New Ventures at Spring Health, I’ve seen how treatment fragmentation hurts lives and how thoughtful program design can change them. A true continuum of behavioral health care isn’t a distant dream—it’s already making a difference today.

    The evolution of employee assistance programs and ACA compliance

    For many employees, an EAP amounts to little more than a crisis hotline. This bare-minimum approach falls far short of what these programs could—and should—be.

    Although employee assistance programs have been around since the early 20th century, their evolution, particularly in addressing substance use disorders and mental health challenges, hasn’t always met employee needs. Key legislation, however, has shaped their role. 

    The 1996 Health Insurance Portability and Accountability Act (HIPAA) introduced distinctions between medical and excepted benefits like EAPs, ensuring health plans extended care beyond the EAP model. The Affordable Care Act (ACA) in 2010 refined these rules with four criteria for excepted EAP benefits:

    1. Benefits aren’t coordinated with other health plan benefits
    2. Employees don’t have to pay premiums or contribute to be enrolled in an EAP
    3. There’s no cost sharing under an EAP
    4. The EAP doesn’t provide significant medical care benefits

    The phrase "significant medical care" is key. A later ACA amendment allows employers to use a “reasonable, good faith interpretation” to determine if an EAP provides significant medical benefits. This language allows employers to prioritize robust employee mental health care without sacrificing ACA compliance.

    Understanding ACA compliance in integrated mental health solutions

    Though the ACA leaves “significant medical care” loosely defined, the behavioral health care field has established some general guidelines. Outpatient mental health care treatments or low-level substance use disorder (SUD) programs under an EAP typically don’t meet the threshold for significant medical care.

    This technicality has a big impact. It allows employee assistance programs to facilitate treatment without the copays, coinsurance, or fragmented care that often deter individuals from seeking behavioral health care or SUD support.

    However, there’s a clear line: higher levels of care, such as intensive outpatient programs or inpatient treatment for eating disorders or detox, must fall under a medical plan. The challenge—and opportunity—is defining that line thoughtfully to ensure members receive seamless care that delivers the best outcomes while remaining ACA-compliant.

    The impact of fragmented behavioral health care on employees

    A common scenario highlights the challenges people face when navigating mental health care. Someone grappling with a deeply personal issue—like trauma or substance use disorder—finally finds the courage to seek help. But instead of finding support, they’re met with a maze of fragmented systems.

    They have to retell their story over and over to new providers. They juggle multiple platforms, pre-authorizations, copays, and referral requirements. Adding to the frustration, they often wait months for appointments, only to discover that many listed providers aren’t even in-network. Discouraged, many give up on getting the care they need

    This fragmentation is one of behavioral health care’s most significant challenges—and it’s a barrier we must overcome.

    Creating seamless behavioral health care models

    The solution to fragmented care lies in reimagining how we connect and deliver support across the entire treatment journey. Building a true continuum of care requires two strategies: creating integrated care platforms and ensuring existing systems work seamlessly together.

    Consider someone managing depression and a substance use disorder. They might need therapy, medication management, and coaching. Under traditional models, each service operates on a separate platform, with different providers and payment requirements—a daunting process, even for someone in great health.

    Integrated care models offer a better way. These platforms focus on the patient experience, ensuring clinical outcomes are prioritized through measurement-based care. Instead of fragmented care, the individual works with a unified care team on a single platform. One login, one story to tell, and no worries about copays or coinsurance.

    This approach transforms the experience, replacing frustration and complexity with seamless, effective support.

    Balancing risk and ACA regulations in mental health care

    As we’ve explored, the ACA’s regulatory framework leaves room for interpretation, particularly around what constitutes significant care. In these gray areas, we prioritize member needs over strict adherence to traditional conservative models.

    For instance, instead of limiting therapy to four sessions, we might provide twelve. If someone has a low-risk substance use disorder, we integrate their care within the EAP framework—avoiding copays and fragmentation—rather than deferring them to a health plan.

    Our approach is rooted in expansive thinking, guided by a risk-adjusted model that addresses member needs while managing downstream impacts like short-term disability claims and workplace productivity. 

    So, what does this look like in practice?

    Integrated EAP and health plan solutions at work

    At Spring Health, we’ve redefined how behavioral health conditions are addressed. Instead of waiting for issues to escalate, we use measurement-based care to identify individuals at risk early. This forms the cornerstone of our continuum of care model—a proactive approach similar to preventative maintenance for mental health.

    Our EAP framework includes:

    • Comprehensive outpatient services tailored to individual needs
    • Case managers who coordinate every aspect of care, acting as administrative quarterbacks
    • Proactive outreach to break down barriers and keep individuals engaged
    • Sophisticated patient-provider matching to connect members with the right providers
    • Wraparound services that ensure no one falls through the cracks

    The impact is profound: 67% of high-risk individuals engage in active care, receiving help before challenges become crises.

    When intensive interventions like inpatient detox or partial hospitalization are needed, our case managers go beyond providing referrals—they ensure smooth transitions, coordinating everything from bed availability to follow-up care.

    This approach reaches vulnerable populations who might otherwise avoid care or drop out, transforming their experience and outcomes.

    Measuring the success of integrated mental health programs

    Our specialty care and substance use disorder program serves dozens of customers and delivers overwhelmingly positive clinical and satisfaction outcomes. By leveraging measurement-based care to identify, engage, and treat high-risk individuals early—on a single platform with specialized care teams—we’re achieving better results while reducing health plan costs.

    The outcomes are significant:

    • 80% reduction in depression and anxiety
    • Similar improvements in substance use
    • Material reductions in medical expenses

    Why does this matter?

    1. Reduced inpatient care: We minimize the need for costly, disruptive inpatient treatment that often requires pre-authorization.
    2. Improved health outcomes: People with substance use disorders typically face worse overall health. By addressing SUD early, we reduce their need for medical care.
    3. Enhanced quality of life: Mental and physical health improvements lead to healthier, happier lives.

    Our data underscores the power of early intervention and continuous care models. It’s a compelling reminder that prioritizing employee wellbeing is also a smart investment for organizations.

    A blueprint for seamless behavioral health care

    For self-insured health plans reevaluating their behavioral health care approach, we recommend focusing on three key priorities:

    1. Put people first. While compliance is essential, prioritize member experience over the most conservative interpretation of ACA regulations regarding excepted benefits.
    2. Partner wisely. Choose behavioral health vendors who understand Mental Health Parity and Addiction Equity Act regulations and can help you stay compliant while delivering outstanding care.
    3. Foster integration. Ensure your health plan and EAP work seamlessly together, building clear bridges that connect members to the right care at the right time.

    The traditional model—waiting until individuals reach a crisis point—leads to expensive, disruptive care that often falls short and increases the risk of relapse. By layering outpatient and specialty services on a single platform, we’re delivering a cohesive experience with consistent, impactful results.

    This model is more than a blueprint for the future—it's already transforming lives and delivering measurable results for employers and employees today.

    Stay prepared for upcoming changes in mental health parity with practical, expert insights from our Senior VP of Payer Strategy.

    About the Author
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    Sean Bell
    General Manager of New Venture

    About the clinical reviewer
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