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NQTLs Health and Welfare Plans Mental Health

McDermott Will & Emery

Anticipating the MHPAEA Final Regulations: A Word About Network Composition

If our trade and industry sources have it right, we could see final regulations implementing the Mental Health Parity and Addiction Equity Act (MHPAEA), as most recently amended by the Consolidated Appropriations Act, 2021...more

McDermott Will & Emery

Lessons from Ryan S. v. UnitedHealth Group for the 2023 MHPAEA Proposed Rule

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A recently decided US Court of Appeals for the Ninth Circuit case, Ryan S. v. UnitedHealth Group, Inc., offers some useful insights on the enforcement by private litigants of the Mental Health Parity and Addiction Equity Act...more

McDermott Will & Emery

The MHPAEA Proposed Rule: ‘Meaningful Benefits’ and the ‘Scope of Services’

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This post continues our consideration of comments submitted in response to proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA). Our previous MHPAEA content is available...more

McDermott Will & Emery

The MHPAEA Proposed Rule: Standards of Care and Medical Necessity

Comments submitted in response to the proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA) reflect a broad range of perspectives. Our previous MHPAEA content is available here....more

McDermott Will & Emery

The MHPAEA Proposed Rule: Scalability and the Plight of the Small(er) Self-Funded Plan

After a brief hiatus to discuss the pleading standards adopted by the US Court of Appeals for the Tenth Circuit in E.W. v. Health Net Life Insurance Company, we return to our examination of the comments submitted in response...more

McDermott Will & Emery

The Proposed MHPAEA Regulations: Comments on Behavioral Health Carve-Out Vendors

McDermott Will & Emery on

This post continues our focus on comment letters submitted in response to proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA). The proposed regulations were issued earlier this year by the US...more

McDermott Will & Emery

The Proposed MHPAEA Regulations: A Comment on the Comments

McDermott Will & Emery on

In our last post, we considered some of the comment letters submitted in response to proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA) issued by the US Departments of Labor, Health and...more

McDermott Will & Emery

The Proposed MHPAEA Regulations’ ‘Meaning of Terms’ Part One: Benefits

McDermott Will & Emery on

This post continues our investigation of proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA) issued by the US Departments of Labor, Health and Human Services and the Treasury (the...more

McDermott Will & Emery

The ‘No More Restrictive’ Requirement for NQTLs Under the Proposed MHPAEA Regulations

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We previously reported on proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA). If adopted in final form, these regulations would vastly complicate compliance by group health plans and health...more

Verrill

DOL Continues Enforcement of Non-Quantitative Treatment Limitation Requirements

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Fifteen months ago, we wrote that the U.S. Department of Labor (“DOL”) had informed Congress that it intended to devote substantial resources to enforcing the new comparative analysis requirement for non-quantitative...more

Snell & Wilmer

Wilderness Therapy – Should We Give It Another Look?

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1. What is it? Wilderness therapy generally is traditional therapy in an outdoor setting that seeks to treat young adults with behavioral or substance use disorders. Some programs are licensed and accredited and the...more

Proskauer - Employee Benefits & Executive...

Proposed Mental Health Parity Guidance Focuses on Nonquantitative Treatment Limitations

On April 23, 2018, the Departments of Labor (DOL), Health and Human Services (HHS) and Treasury (together, the “Agencies”) released proposed frequently asked questions (“FAQs”) related to nonquantitative treatment limitations...more

Proskauer - Employee Benefits & Executive...

Proposed Mental Health Parity Guidance Would Impose Burdensome Disclosure Requirements

On April 23, 2018, the Departments of Labor (DOL), Health and Human Services (HHS) and Treasury (together, the “Agencies”) released proposed frequently asked questions (“FAQs”) related to required disclosures and...more

Snell & Wilmer

Recent Mental Health Parity Guidance — A Good Reminder to Review Your Health Plan for Compliance

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The Mental Health Parity and Addiction Equity Act of 2008 (“MHPAEA”) generally requires that the financial requirements and treatment limitations that apply to mental health and substance use disorder (“MH/SUD”) benefits...more

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