Summary The Departments of the Treasury, Labor, and Health and Human Services have published final regulations under the Mental Health Parity and Addiction Equity Act that prohibit group health plans and health insurers from imposing nonquantitative treatment limitations that place greater restrictions on benefits for mental health and substance use disorders than for medical and [&hellip… Continue Reading »
Summary The Departments of Labor, Health and Human Services, and the Treasury have proposed regulations under the Mental Health Parity Act that build on prior guidance to set forth requirements for an extremely detailed analysis of how a health plan’s nonquantitative treatment limitations (NQTLs) for mental health and substance use disorder benefits compare to those [&hellip… Continue Reading »
Summary On July 25, 2023, the Departments of Labor, Treasury, and Health & Human Services (the Departments) released joint proposed regulations and other guidance under the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008 (the MHPAEA). This alert provides a high-level summary of the much-anticipated guidance; a more detailed analysis of [&hellip… Continue Reading »
Summary The Departments of the Treasury, Labor, and Health and Human Services jointly issued a report to Congress, fulfilling obligations that they have with regard to the Mental Health Parity and Addiction Equity Act (MHPAEA) and Consolidated Appropriations Act, 2021 (CAA). The report offers valuable insight into the departments’ approach to enforcing the MHPAEA and, [&hellip… Continue Reading »
Summary This is the second briefing in our series on the Consolidated Appropriations Act, 2021 (CAA) and transparency regulations. It concerns a new rule under the Mental Health Parity and Addiction Equity Act (MHPAEA) that requires health plans to conduct and document an analysis that compares the nonquantitative treatment limitations applicable to benefits for mental [&hellip… Continue Reading »
Summary Throughout 2020 and 2021, employers sponsoring health and welfare plans have needed to respond to a myriad of legislative and regulatory changes arising from the COVID-19 pandemic and new health legislation. To comply with these changes, employers may need to work with their vendors, amend their plans, and take other action. In this alert, [&hellip… Continue Reading »
The 21st Century Cures Act set the stage for additional guidance to be issued under the Mental Health Parity and Addiction Equity Act (MHPAEA) and increased enforcement of its requirements. In a recent set of proposed frequently asked questions and answers, the Departments of Labor, Health and Human Services, and the Treasury provided examples of [&hellip… Continue Reading »
The Equal Employment Opportunity Commission (EEOC) has issued guidance reminding employers that it is illegal under the Americans with Disabilities Act (ADA) and other laws to discriminate against an employee simply because he or she has a mental health condition. This includes firing an employee, rejecting an employee for a job or promotion, and forcing [&hellip… Continue Reading »
