New Mental Health Parity Final Rule: NQTL Requirements, Insurer and Plan Sponsor Impact, Compliance Timeline

BARBRI

This CLE webinar will provide a comprehensive overview of the recently released final rule issued by the U.S. Departments of Health and Human Services, Labor, and the Treasury that implements the non-quantitative treatment limit (NQTL) aspects of the Mental Health Parity and Addiction Equity Act (MHPAEA) to ensure parity between mental health/substance use disorder benefits (MH/SUD) and medical/surgical benefits (M/S). The panel will discuss the impact on covered entities and offer best practices for compliance.

Description

A new final rule recently issued by HHS, Labor, and the Treasury implements the NQTL aspects of the MHPAEA and is part of an ongoing effort to ensure parity between MH/SUD and M/S. Certain requirements will be effective for group health plans as early as Jan. 1, 2025 with other requirements delayed until 2026.

NQTLs are non-numerical limits on the scope or duration of benefits for treatment (e.g., preauthorization requirements; plan methods for determining usual, customary, and reasonable charges; and restrictions based on geographic location, facility type, provider specialty, and other criteria that limit the scope or duration of benefits for services provided under the plan or coverage).

The final rule applies to nearly all forms of commercial health benefits and insurance in the U.S. Key provisions of the final rule include:

- Prohibiting the application of an NQTL on MH/SUD benefits that is more restrictive than the predominant NQTL applied to substantially all M/S benefits in the same classification;
- Collecting and analyzing data and addressing differences in access to MH/SUD care as compared to M/S benefits;
- Performing comparative analyses to measure the impact of NQTLs per the new rule's requirements; and
- Prohibiting the use of discriminatory information when designating NQTLs.

Counsel should understand the final rule to assist clients with navigating the expansive new requirements.

Listen as our expert panel provides a comprehensive overview of the final rule's requirements for parity of MH/SUD benefits under the MHPEA. The panel will address the impact on covered providers and provide best practices for compliance.

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