Parity ‘Warning Signs’ And An Employer Shared Responsibilty Estimator

The Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA), as amended by the Affordable Care Act, requires that group health plans and insurers in the group and individual markets ensure that financial requirements and treatment limitations on mental health and substance use disorder (MH/SUD) benefits are no more restrictive than requirements and limitations imposed on medical and surgical benefits. This prohibition applies both to quantitative (numerical) limitations, like visit limits, and to non-quantitative (NQTL-non-numerical), limitations such as pre-authorization requirements. Under the MHPAEA regulations, a plan or insurer may not impose an NQTL on MH/SUD benefits unless, under the written terms of the plan and in practice, any processes, strategies, evidentiary standards, or other factors used in applying the NQTL to MH/SUD benefits in a classification are comparable to, and applied no more stringently than, those used and applied with respect to medical surgical benefits in the same classification. On June 1, 2016, the departments of HHS and Labor issued a list of plan provisions identified as “warning signs” that should “trigger careful analysis” to compare terms applied to medical/surgical coverage to determine whether a violation of the MHPAEA might be present. The provisions do not automatically violate the law, as long as they are applied equally to medical/surgical benefits, and the list is not exhaustive. Each term is described in greater det...
Source: Health Affairs Blog - Category: Health Management Authors: Tags: Equity and Disparities Following the ACA Insurance and Coverage employer coverage mental health and substance use disorder parity Source Type: blogs