CHA News Article

Non-Quantitative Treatment Limitations Outlined for Health Plans
May trigger need for parity analysis

The Department of Labor’s Employee Benefits Security Administration (EBSA) has posted a new fact sheet to help identify whether health plans are in compliance with the Mental Health Parity and Addiction Equity Act (MHPAEA) and regulations. The document includes examples of plan provisions for mental health/substance use disorders — including copays, visit limits and preauthorization requirements — which the agency says should trigger careful analysis of medical/surgical coverage to ensure MHPAEA compliance. According to the EBSA, language included in the document can indicate red flags that a plan or issuer may be imposing an impermissible requirement. However, further review of the processes, strategies and factors used in applying the requirement must be conducted to determine parity compliance.