Last week, the Departments of Labor, Treasury, and Health and Human Services finalized regulations implementing the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA). Although the final regulations step back from certain burdensome aspects of the proposed rules (which we blogged about here), compliance with the final rules will require action from
Mental Health Parity
District Court Dismisses Class Action Seeking Wilderness Therapy Benefits
By Sydney Juliano & Jennifer Rigterink on
A federal district court rebuffed putative class claims alleging that Cigna Health and Life Insurance Co. and two of the plans it administered violated the Mental Health Parity and Addiction Equity Act of 2008 (“MHPAEA”) by denying coverage for wilderness therapy. S.F. v. CIGNA Health & Life Ins. Co., 2024 WL 1912359 (D. Utah…
Proposed MHPAEA Regulations Flowchart: Understanding the New Framework for Non-Quantitative Treatment Limitations
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…
Proposed Mental Health Parity Regulations Arrive: Key Changes for Plan Sponsors
By Jennifer Rigterink on
On Tuesday, the Departments of Labor, Treasury, and Health and Human Services issued proposed amendments to regulations implementing the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA) and new regulations implementing the non-quantitative treatment limitation (NQTL) comparative analysis requirements under MHPAEA. The proposed regulations introduce sweeping changes that would affect virtually all group health plans that cover mental health and substance use disorder benefits.
By way of background, MHPAEA requires that group health plans provide mental health and substance use disorder (MH/SUD) benefits in parity with medical and surgical benefits. Evaluation of whether benefits are in parity is performed for each classification of benefits under the plan. Although seemingly simple in concept, the nuanced nature of the parity rules has made application challenging for many plan sponsors. Below are three key areas of focus in the proposed rules that would significantly impact group health plan administration: