Parity, level-of-care, safety
MHPAEA parity is not a checkbox. It is a documentary obligation that re-tests on every UM decision. Owl reads every progress note, every level-of-care assessment and utilization memo, walks ASAM, LOCUS and CALOCUS criteria, and writes a parity-defensible determination with a medical comparator.
NQTL parity
Med-surg comparator drafted
64%
Overturn risk if denied
$0
Avoidable cost of a wrongful denial
Three AI agents on a BH file. Reading. Cross-referencing. Answering.
One IOP step-down: a parity-defensible determination in 1.7 seconds.
Anonymized composite. Member 32M, MDD + GAD, completing PHP and requesting IOP step-down. The carrier denied medical necessity; this is the post-denial reconstruction.
External data only. None of this lives in your CMS. Owl gathered it from public records, professional networks, registries and the open web, then resolved it to this claimant.
Plan’s medical-surgical comparator (cardiac rehab Phase II) auto-approves at LOCUS-equivalent severity 87% of the time. Denying IOP at LOCUS 4 with documented step-down clinical basis creates an NQTL parity disparity exposure under MHPAEA, reportable to DOL and state DOI.
Owl IRO corpus (n=180K) shows IOP step-down denials at LOCUS 4 with completed PHP overturn at 64%. Procedural denial language ("no medical necessity documented") triggers an additional procedural-defect bump on appeal.
State Prescription Drug Monitoring Program shows a benzodiazepine fill from an out-of-network ED on 2025-08-09, not entered in the chart. Increases acuity argument for continued IOP-level structure; route to care manager.
ASAM Dimensions 5 (relapse / continued use potential) and 6 (recovery environment) both support continued structured care at the IOP level. LOCUS 4 criteria fully met.
IOP is medically necessary, and the denial is not parity-defensible. Clinically, the member completed PHP at LOCUS 4 with continued mood instability, a recent passive-SI crisis, and a recent out-of-network benzodiazepine fill surfaced via PDMP. ASAM Dim 5/6 and LOCUS 4 both support continued structured care at IOP. The plan’s medical-surgical comparator (cardiac rehab Phase II) auto-approves at equivalent severity 87% of the time, creating MHPAEA NQTL disparity if BH IOP is denied. Recommend overturn and approve.
NQTL comparator: medical-surgical analog is post-acute structured rehabilitation (cardiac Phase II / pulmonary). Plan policy auto-approves cardiac Phase II at NYHA Class III equivalent severity 87% without secondary review. The proposed BH IOP review process (chart re-review + manual UM) imposes a more stringent process than the comparator. Under MHPAEA NQTL "no more restrictive" standard, the BH process is non-compliant as designed. Memo drafted with side-by-side citations to plan policy and DOL guidance.
What the world says about your Behavioral health claimants, none of which lives in your CMS.
Internal claim data is half the picture: it tells you what the claimant told you. OwlSignal continuously gathers external data (public records, professional and corporate registries, court dockets, social and open web) and matches it back to the claimant. These are the families that move the needle on Behavioral health.
Medical-surgical NQTL comparator data (what the plan does on cardiac rehab, pulmonary rehab, post-acute SNF and home health) to test BH determinations against MHPAEA "no more restrictive" standard.
ASAM, LOCUS, CALOCUS, CMS, MCG and InterQual BH criteria: walked element-by-element on every level-of-care decision, with version cites attached.
State PDMP and cross-PBM pharmacy data: controlled-substance fills, opioid + benzodiazepine activity, MAT history. Often material to acuity arguments and to safety planning.
IRO decisions from state DOIs and CMS: what gets overturned on BH denials, by severity and by LOC. Owl’s corpus is 180K decisions across 14 states.
OIG LEIE, state behavioral-health board sanctions, DEA action database, Owl’s cross-payer prescribing graph and BH provider outcomes graph.
Plan EOC, BH medical policy library, medical-surgical comparator policies, NQTL design documentation. Read once, walked on every BH determination.
Numbers from health plans running Owl on BH UM in production.
Built for the regulatory shape of Behavioral health.
Lives where your Behavioral health files live.
Core admin
HealthEdge, Trizetto Facets, QNXT
UM platforms
GuidingCare, Aerial, ZeOmega Jiva, MedHOK
BH-specific
Headway, Brightside, Lyra, Spring Health, Carelon BH
EHR / records
Epic, Cerner, NextGen, Welligent, Streamline
Criteria libraries
ASAM, LOCUS, CALOCUS, MCG, InterQual
Identity & SSO
Okta, Azure AD, PingFederate, SAML, SCIM
Bring us a quarter of BH denials. We’ll show you the parity exposure on day one.
Two-week pilot. Your BH stream, your tenant, your medical policy. We measure cycle time, IRO survival, NQTL comparator quality and DOL audit-readiness against your own ground truth.