News & Analysis as of

NQTLs Department of Labor (DOL) Consolidated Appropriations Act (CAA)

Foley & Lardner LLP

Final Mental Health Parity Rules – Top Five Changes to the Status Quo

Foley & Lardner LLP on

The Mental Health Parity and Addiction Equity Act and its implementing regulations and guidance (MHPAEA) prohibit health insurance policies and group health plans that cover mental health and substance use disorder (MH/SUD)...more

McDermott Will & Emery

Six Wishes for the Forthcoming Final Regulations Under MHPAEA

McDermott Will & Emery on

On July 1, 2024, the US Department of Labor (DOL) submitted final regulations to the Congressional Budget Office (CBO), implementing the Mental Health Parity and Addiction Equity Act (MHPAEA) as most recently amended by the...more

Snell & Wilmer

2023 End-of-Year Plan Sponsor “To Do” Lists (Part 1) Health and Welfare

Snell & Wilmer on

We are pleased to present our annual End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate Employee Benefits Updates. This Part 1 covers year-end health and welfare plan issues....more

Holland & Hart - The Benefits Dial

The Time Has Come, A Fact’s A Fact: Consider Adding a Welfare Plan Committee

The time may have come to add a welfare plan committee to your company’s governance of employee benefit plans. New legal obligations and other developments impose fiduciary risks for welfare plans similar to what already...more

Foley & Lardner LLP

Action Steps Health Plans Should Take Now In Response To New DOL Guidance on Mental Health Parity

Foley & Lardner LLP on

The Consolidated Appropriations Act, 2021 (CAA) added a requirement for health plans to document their compliance with nonquantitative treatment limitations (NQTLs) under the Mental Health Parity and Addiction Equity Act...more

Seyfarth Shaw LLP

Mental Health Compliance Report Issued to Congress Spoiler Alert – Plans All Fail

Seyfarth Shaw LLP on

Seyfarth Synopsis: The Mental Health Parity and Addiction Equity Act (MHPAEA) requires group health plans and insurers to cover treatments for mental health and substance use disorders in a manner that is equitable to the...more

Holland & Hart - The Benefits Dial

Better Hide the Wine … Employer Considerations as the DOL Doubles Down on Mental Health Parity Compliance in New Proposed...

The Department of Labor (DOL), the Department of Health and Human Services (HHS), and the Department of Treasury (collectively, the Departments) recently issued proposed Mental Health Parity and Addiction Equity Act (MHPAEA)...more

King & Spalding

HHS, the Department of Labor, and the Department of the Treasury Release Proposed Rules and a Report to Congress regarding Mental...

King & Spalding on

On July 25, 2023, HHS, the Department of Labor, and the Department of the Treasury (the Departments) issued proposed rules (Proposed Rules) and other information regarding health plan and issuer compliance with mental health...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Proposed Rules Push Mental Health Parity Up Benefit Priority List

Now you know. It could not be any clearer to employers that compliance with the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA) will be a—maybe the—top health and welfare benefit priority for federal...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Mental Health Parity Compliance Remains a Key Focus for Federal Agencies

On July 25, 2023, the U.S. Department of Labor (DOL), the U.S. Department of Health and Human Services (HHS), and the U.S. Department of the Treasury released their annual report to the U.S. Congress regarding group health...more

Manatt, Phelps & Phillips, LLP

First Look at Proposed New Federal Mental Health Parity Rules

Last week, the departments of the Treasury, Labor and Health and Human Services (collectively, the Departments) published long-awaited proposed regulations intended to clarify and improve compliance with the federal mental...more

Verrill

DOL Signals Heightened Enforcement of Non-Quantitative Treatment Limitation Requirements

Verrill on

Introduction. When the U.S. Department of Labor issued its biennial 2022 Mental Health Parity and Addiction Equity Act (“MHPAEA”) Report to Congress earlier this year, it outlined significant noncompliance by health plans....more

Foley & Lardner LLP

Behavioral Health Trends for 2022

Foley & Lardner LLP on

Over the last two years, behavioral health (BH) has been one of the biggest growth areas in the health care ecosystem, fueled by the Public Health Emergency (PHE) but in many ways an ignored, overlooked, understaffed, and...more

Verrill

Deciphering First Circuit’s Thirty-page Primer on NQTL Analysis and ERISA Information Requests

Verrill on

The widely publicized 2022 Report to Congress regarding the Mental Health Parity and Addiction Equity Act (“Parity Act”) forewarned greater enforcement efforts by the Department of Labor and highlighted suspected deficiencies...more

Foley & Lardner LLP

Health Plans’ Prior Authorization Rules are under Scrutiny by the DOL for Mental Health Parity Compliance – See the DOL’s Top Five...

Foley & Lardner LLP on

On January 25, 2022, the U.S. Departments of Labor (“DOL”), Treasury, and Health and Human Services (the “Departments”) provided a report (the “Report”) on Mental Health Parity and Addiction Equity Act (“MHPAEA”) compliance...more

Holland & Hart - The Benefits Dial

What Happens in a Small Town Stays in a Small Town … Until the DOL Doubles Down on Mental Health Parity Compliance

The Department of Labor (DOL), the Department of Health and Human Services (HHS), and the Department of Treasury (collectively, the Departments) recently issued their joint report to Congress regarding their Mental Health...more

Epstein Becker & Green

2022 Mental Health Parity Report to Congress Highlights Increased Enforcement Efforts

On January 25, 2022, the U.S. Department of Labor (“DOL”), Department of Health and Human Services, and Department of the Treasury (collectively, “Departments” or “Regulators”) released their 2022 Annual Report to Congress on...more

Sheppard Mullin Richter & Hampton LLP

Tri-Agencies Report MHPAEA Compliance Lacking, But Don’t Name and Shame Plans and Issuers . . . Yet

On January 25, the U.S. Department of Labor (DOL), Department of Health and Human Services (HHS), and the Treasury (collectively the Tri-Agencies) published the first annual report on group health plans’ and health insurance...more

Manatt, Phelps & Phillips, LLP

Federal Regulators Issue Joint Report on MHPAEA Signaling Increased Enforcement Against Plans Likely

On Tuesday, the U.S. Departments of Labor, Health & Human Services, and the Treasury (the Departments) issued their joint report to Congress on the Mental Health Parity and Addiction Equity Act (MHPAEA). The Consolidated...more

Morgan Lewis

A Survival Guide to DOL Group Health Plan Mental Health Parity Audits

Morgan Lewis on

The Consolidated Appropriations Act of 2021 mandates that employers offering medical/surgical and mental health/substance use disorder coverage provide comparative analyses and any supporting documentation demonstrating...more

Verrill

Self-Insured Group Health Plan Sponsors: Action Steps to Mitigate Risk Under the Mental Health Parity and Addiction Equity Act

Verrill on

The Mental Health Parity and Addiction Equity Act (“MHPAEA”) provisions of the Consolidated Appropriations Act, 2021 (“CAA”) introduced a requirement that group health plans and insurance providers offering both medical and...more

Snell & Wilmer

Departments Provide Some Relief to Health Plan Sponsors Facing Looming Year-End Deadlines

Snell & Wilmer on

Year-end is always a scramble for health plan sponsors as they go through renewal and open enrollment. This year was looking to be worse than normal given the impending deadlines for complying with the transparency in...more

Groom Law Group, Chartered

Mental Health Parity Remains a Priority for Tri-Agency: MHPAEA Compliance in Response to the CAA

The Mental Health Parity and Addiction Equity Act of 2008’s (“MHPAEA”) provisions of the Consolidated Appropriations Act, 2021 (the “CAA”) became effective February 10, 2021 and added a requirement for group health plans and...more

Foley & Lardner LLP

The DOL Has Made This New Mental Health Parity Requirement a Top Enforcement Priority

Foley & Lardner LLP on

Embedded in the Consolidated Appropriations Act, 2021 (the “CAA”) is a new obligation for group health plan sponsors and insurers that provide health insurance to document that their group health plan or insurance policy...more

Epstein Becker & Green

Podcast: What's New for Insurers in Mental Health Parity Compliance - Diagnosing Health Care

Epstein Becker & Green on

The Departments of Labor, Health and Human Services, and the Treasury jointly released a set of frequently asked questions (“FAQs”) related to recent changes made to the Mental Health Parity and Addiction Equity Act effective...more

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