MHPA - something wrong?

[Guest tintree73]

In negotiations w/ union. They want us to modify our self-insured plan to provide the same coinsurance amount for medical/surgical and mental health benefits but want us to continue to keep the visit limitation (e.g., 30 visits) for only mental health benefits.

I generally understand the MHPA to prohibit dollar or lifetime maximums for mental health than medical/surgical benefits, but I think the MHPA says that the plan can still have coinsurance, co-pays, limits on the number of visits, etc. on mental benefits are ok - if it does not result in a combined limit that would act as an annual limit. For instance, I looked at the DOL's website and there is an example where when you combine a dollar limit with a limit on the number of visits - that this constitutes a combined limit that is akin to an annual limit (not allowed by the MHPA if the same limits are not placed on medical/surgical) - e.g., 50 visits allowed per year and $40 paid per visit would be an annual limit of $2,000 on mental health benefits that does not apply to medical/surgical benefits.

Does the coinsurance suggested by the union work the same way (e.g., the 20% coinsurance x 30 visits could be an annual limit too?).

Or am I thinking wayyyy to much about all of this?