On behalf of Pyramid Healthcare, attached please find written testimony in support of SB524/HB656: "Mental Health & Substance Abuse Disorders; Network Adequacy Standards, Comparative Analyses, Report." Sincerely, Collan B. Rosier Vice President of Government Relations Pyramid Healthcare, Inc.

HB656: When affordability of healthcare is at such a risk right now, the solution can never be adding more and more onerous paperwork and privacy-leaking documentations for mammoth databases which can be hacked with user PII de-anonymized. We need to vastly reduce the number of such databases held by the state. Instead of this law, host a videotaped roundtable with subpoenas for particular info. In this particular case, demanding info on unpaid claims and uncovered benefits invites lawfare from the corporations which have alot of money to fight .This language implies they have to report not only what they cover but what they never would have dreamed of covering. If I told you: tell me all the expenses you didn't incur , and tell me all the expenses you would have incurred if you had different priorities, what would you say? It's non-objective. Separately, as I understand, HB1380, also on this topic is simply edits for clarity which is good.

See attached.

Dear Chair Gardner: The Association for Behavioral Health and Wellness (ABHW) writes to oppose House Bill 656 relating to mental health and substance use disorders. ABHW is the national voice for payers managing behavioral health (BH) insurance benefits. Our member companies provide coverage to 200 million people in the public and private sectors to treat mental health (MH), substance use disorders (SUDs), and other behaviors that impact health and wellness. Since its inception, ABHW has been at the forefront of and an advocate for MH and SUD parity. We were instrumental in drafting the federal legislation for the initial Mental Health Parity and Addiction Equity Act (MHPAEA) of 2008, and our members have worked tirelessly over the past 16 years to implement parity for behavioral health services. Our organization aims to increase access, drive integration, support prevention, raise awareness, reduce stigma, and advance evidence-based treatment and quality outcomes. Please see our attached written comments. Thank you, Debbie Witchey, MHA President and CEO

I am writing as a licensed mental health provider and constituent to urge you to support the Mental Health Parity and Network Adequacy legislation introduced by Senator Creigh Deeds. In my clinical practice, I see firsthand how insurer practices undermine access to care for individuals struggling with mental health and substance use disorders. Despite longstanding parity laws, reimbursement, authorization, and network practices continue to disadvantage mental health treatment compared to medical and surgical care. I have personally experienced insurers paying higher rates to large intermediary companies than to independent clinicians providing the same services. At the same time, reimbursement for mental health providers remains below parity with similarly trained medical professionals. These practices contribute directly to provider burnout, network attrition, and reduced access for patients. The data supporting this bill reflects what providers and patients already know: * Mental health and substance use networks are shrinking rapidly. * Denials for behavioral health care far exceed those for medical services. * Office and outpatient services face disproportionate barriers. * Patients routinely report difficulty accessing timely care. * Parity violations have been documented across major carriers. * Appeals frequently fail, leaving vulnerable individuals without treatment. This legislation is critically important because it moves beyond symbolic parity and creates real accountability. By defining mental health benefits using recognized diagnostic standards, requiring transparent comparative analyses, collecting reimbursement data, enforcing penalties, and establishing enforceable network adequacy standards, this bill addresses the structural causes of access failures. Without meaningful enforcement, parity laws remain ineffective. Providers continue to leave networks, and patients are left without care during moments of greatest need. This bill represents a necessary step toward restoring fairness, stability, and access within Virginia’s behavioral health system. I strongly urge you to support this legislation and stand with providers and patients who depend on a functioning, equitable mental health system. Thank you for your time, your leadership, and your commitment to the wellbeing of Virginians. Respectfully, Emilie Ferran, LPC, ATR

See attached comments with our reasoning for our support.

Please vote for HB 656 to strengthen mental health parity in Virginia. As a Licensed Clinical Social Worker, public sector professional and someone who has experienced the impact on mental health challenges on loved ones, it is critical that treatment access is a priority not left as a challenge to individuals who seek help. Behavioral health is HEALTH- timely access to necessary services saves lives. Hold insurance companies accountable to parity and network adequacy standards. Force them to remove un-necessary administrative barriers that undercut behavioral health providers and the medically necessary work they perform. It is time that Mental Health Parity requirements are fully implemented in Virginia

As a licensed counselor in Virginia with over 30 years of experience, I can attest to how difficult it is for many residents to access counseling through their insurance in a reasonable timeframe. Inadequate behavioral health networks and long delays in care are common, even when individuals are motivated to seek help. Delayed or unavailable mental health care can worsen depression and anxiety, contribute to physical symptoms, and increase the risk of crisis. Many of these situations could be mitigated if individuals with emerging or urgent mental health needs were able to see a licensed clinician promptly, rather than relying on emergency rooms as a last resort. HB 656 addresses these challenges by strengthening network adequacy standards and requiring greater accountability from insurers. Treating behavioral health according to the same standards as physical health care would improve access for consumers and encourage more clinicians to participate in insurance networks. For all of these reasons, I hope that the legislature will adopt HB 656.

The Charlottesville Mental Health Consortium strongly supports this bill. As a group of mental health providers who are keenly aware of the difficulty citizens have in receiving mental health services due to lack of parity, we support this effort to enhance enforcement of the mental health parity standards.

As a mental health provider in the state of Virginia who has observed the many ways in which insurance providers are ignoring the mental health parity law I strongly urge this committee to move this bill forward

Virginia continues to rank near the bottom of all the states in access to a mental health professional, and it's getting worse as more professionals stop taking insurance. Increased enforcement of parity laws is needed so more providers will be available to people in need of help. Having worked in mental health awareness and advocacy for several years, I have heard the stories from so many people just wanting to feel better and not escalate into crisis. This bill will help.

As a mental health private practice owner and licensed clinical social worker that provides remote mental health therapy in the state of Virginia and who has observed the many ways in which insurance providers are ignoring the mental health parity law I strongly urge this committee to move this bill forward.

We support HB 656. The attached testimony provides more detailed comments. Thank you.