Mental Health Parity and Addiction Equity Act
March 12, 2021//Comments Off on Mental Health Parity and Addiction Equity Act
On December 27, 2020, the Consolidated Appropriations Act, 2021, was signed into law. According to the new legislation, employer sponsored group health plans must review their compliance with the Mental Health Parity and Addiction Equity Act (MHPAEA). The Act requires group health plans that offer both medical and surgical benefits and mental health or substance use disorder benefits that impose nonquantitative treatment limitations (NQTLs) on mental health or substance use disorder benefits to perform and document comparative analyses of the design and application of NQTLs. NQTLs are the processes, strategies, evidentiary standards or other criteria that limit the scope or duration of benefits. NQTL examples can include medical management standards, formulary designs for prescription drugs, network tier designs, exclusions, credentialing requirements of providers, and geographic, facility type, or provider specialty type restrictions. The comparative analyses must be made available to a state authority, the secretary of the US Department of Labor (DOL), or the secretary of the US Department of Health and Human Services (HHS) beginning 45 days after the enactment of the Act, but only upon request from those agencies. Plan sponsors should be prepared to provide the comparative analyses on or after February 10, 2021. Even though the agencies can start requesting analyses from plan sponsors at any time, it is not likely to occur before additional guidance is released. The Act advises that guidance is expected within the next 18 months Please be advised that this content has been prepared for informational purposes only and should not be relied on for legal or tax advice. This information is subject to change as guidance develops. |
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