August 23, 2024
The Mental Health Parity and Addiction Equity Act (MHPAEA) continues to be an enforcement priority for the Department of Labor, yet many compliance questions remain. The NFP Benefits Compliance team recently held a webinar featuring a conversation on MHPAEA requirements and practical compliance insights as we addressed the questions employer plans may be too embarrassed to ask.
Agenda
- History and Overview
- Comparative Analysis
- Enforcement
- Lawsuits
- Common Questions
- Compliance Takeaways
Key Takeaways
Employer Considerations
- MHPAEA is not new but recent guidance means increased enforcement efforts.
- Top DOL enforcement priority for 2024 and beyond.
- Plans need to have a comparative analysis prepared to demonstrate compliance with nonquantitative treatment limitations (NQTLs) requirements.
- Employers can’t fix NQTL problems alone (need to justify or remove problematic NQTLs).
- Start by reviewing your plan for red flags.
- Fully insured employer/plan sponsors should communicate with carriers regarding compliance with the comparative analysis requirement.
- Self-insured employer/plan sponsors should communicate with their third-party administrator (TPA) and review any administrative services agreements.
- Work with legal counsel to fix any problematic NQTLs.
- Pay attention to participant complaints.
- Keep an eye out for new developments.
NFP Resources
For further information, please ask your broker or consultant for a copy of the NFP publication MHPAEA Compliance: Red Flag NQTLs.
Watch for any latest announcements and benefits news through NFP's Compliance Corner.