On September 5, 2019, the DOL, IRS, and HHS (the Departments) released a number of documents concerning mental health parity compliance, including a finalized FAQ. As background, the Mental Health Parity and Addiction Equity Act (MHPAEA) requires that the financial requirements and treatment limitations imposed on mental health and substance use disorder (MH/SUD) benefits be no more restrictive than the predominant financial requirements and treatment limitations that apply to substantially all medical and surgical benefits. MHPAEA also imposes several disclosure requirements on group health plans and health insurance issuers.
In addition to finalizing FAQs About Mental Health and Substance Use Disorder Parity Implementation and the 21st Century Cures Act Part 39, the Departments also released a claims form that individuals can use to request documentation about their plan’s mental health treatment limitations, and three documents highlighting the DOL’s 2018 enforcement of MHPAEA. See below for a recap on each of those resources.
FAQs About Mental Health and Substance Use Disorder Parity Implementation and the 21st Century Cures Act Part 39
This document provides additional guidance to employers and individuals about the application of the law. The finalized rules make slight changes to the proposed version by providing certain clarifications and adding additional examples. Here is an overview of the 11 questions addressed in this document:
* Questions 1-8 address different nonquantitative treatment limitation issues, including experimental or investigative treatment limitations, prescription drug dosage limitations, step therapy and fail first policies, reimbursement rates for physicians and non-physicians, network adequacy, and medical appropriateness. One question also clarifies that plans can choose to exclude coverage for certain specific mental health conditions, as long as other federal or state laws don’t prohibit the exclusion.
* Questions 9-11 discuss MHPAEA’s disclosure requirements. Specifically, the Departments discuss the model form that individuals can use to request plan information about their MH/SUD benefits. They also remind employers that they can provide a hyperlink or URL address where participants can access their provider directory, but that directory must be up-to-date and accurate so that participants can access correct information pertaining to MH/SUD providers.
Source: NFP BenefitsPartners
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