In late July, the Departments of Labor, Treasury, and Health and Human Services released proposed regulations implementing the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA).  Readers of our previous blog will recall that the proposed regulations include a new three-part framework for evaluating “non-quantitative treatment limitations” (NQTLs) imposed on plan benefits.  NQTLs refer to non-numerical limitations on the scope or duration of plan benefits, such as prior authorization requirements.  We have prepared a flowchart illustrating the new framework in the proposed rules, which can be downloaded here.