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
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:
On January 9, 2014, the Departments of Treasury, Labor, and Health and Human Services (collectively, the “Departments”) published the eighteenth installment of a series of answers to Frequently Asked Questions regarding implementation of the Affordable Care Act (ACA) and the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA).
The FAQ provides guidance on…