News & Analysis as of

NQTLs Mental Health MHPAEA

Troutman Pepper

White House Finalizes New Mental Health Parity Rule

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The White House has finalized the new Mental Health Parity rule, which focuses on increasing access to mental health/substance use disorder treatment through nonquantitative treatment limitations (NQTL) data and reporting,...more

Seyfarth Shaw LLP

Agencies Release Final Mental Health Parity Rule

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On Monday, September 9, 2024, the Departments of Health and Human Services, Labor and Treasury (the “Departments”) issued their final rule regarding the nonquantitative treatment limitation (NQTL) comparative analysis...more

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

Six Wishes for the Forthcoming Final Regulations Under MHPAEA

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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

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

Husch Blackwell LLP

Mental Health Parity and Addiction Equity Act: Comprehensive Final Rule Expected in 2024

Husch Blackwell LLP on

In the United States, mental health (“MH”) and substance use disorder (“SUD”) (collectively “MH/SUD”) have continued to represent areas of intense concern. During the COVID-19 pandemic, the MH struggles of essential workers...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

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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

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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

Discerning Congressional Purpose from the Proposed MHPAEA Regulations Comment Letters

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We continue 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 Departments)...more

Davis Wright Tremaine LLP

New Mental Health Parity Guidance Creates More Work, Cost, and Risk for Plan Sponsors

Guidance on the Mental Health Parity and Addiction Equity Act (the "MHPAEA") recently released by the Departments of Health and Human Services, Labor, and Treasury (the "Departments") proposes significant requirements for...more

McDermott Will & Emery

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

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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 “Meaningful Benefit” Requirement for NQTLs Under the Proposed MHPAEA Regulations

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In previous posts, we reported on proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA) issued by the Departments of Labor, Health and Human Services, and the Treasury (collectively, the...more

McDermott Will & Emery

The ‘Data Evaluation Requirement’ for NQTLs Under the Newly Proposed MHPAEA Regulations

Last week’s post examined the “no more restrictive” requirement that would apply to non-quantitative treatment limitations (NQTLs) set out in recently proposed regulations under the Mental Health Parity and Addiction Equity...more

Alston & Bird

Agencies Issue Extensive MHPAEA Guidance: Plan and Issuer Action Required

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Our Employee Benefits & Executive Compensation Group summarizes the key provisions of a proposed rule that would impose new Mental Health Parity and Addiction Equity Act requirements on group health plans and health insurance...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

Jackson Lewis P.C.

A Current Roadmap for Complying with Mental Health Parity Requirement

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Most employers know that if a group health plan provides mental health or substance use disorder (MH/SUD) benefits in any of six specified classifications, the plan must provide MH/SUD benefits in all specified...more

Troutman Pepper

Proposed Mental Health Parity and Addiction Equity Act Rules Clarify Technical Compliance Requirements, But Practical Challenges...

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On July 25, the Departments of Labor, Health and Human Services, and the Treasury (Departments) jointly issued highly anticipated guidance on mental health and substance use disorder benefits. The guidance takes the form of...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

Seyfarth Shaw LLP

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

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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

Seyfarth Shaw LLP

Mental Health Request for Public Comment Spoiler Alert – The Departments Need Help

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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

Seyfarth Shaw LLP

Mental Health Parody: In A Cruel Prank, Agencies Respond to Employer Pleas for Guidance with More Stringent Regulations

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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

McDermott Will & Emery

New MHPAEA Guidance Regarding NQTLs: Network Access and Composition

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Recently proposed regulations attempt to ensure that health plans allow access to mental health or substance use disorder (MH/SUD) benefits as easily as medical or surgical (M/S) benefits. The proposed regulations, issued by...more

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