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Text of DOL/HHS Checklist: Plan or Policy Non-Quantitative Treatment Limitations That Require Additional Analysis to Determine Mental Health Parity Compliance (PDF)
U.S. Department of Labor [DOL] and U.S. Department of Health and Human Services [HHS]
[Official Guidance] June 2, 2016
"Language contained in [provisions listed in this checklist] (absent similar restrictions on med/surg benefits) can serve as a red flag that a plan or issuer may be imposing an impermissible [Non-Quantitative Treatment Limitation (NQTL)]. Further review of the processes, strategies, evidentiary standards, or other factors used in applying the NQTL to both [Mental Health or Substance Use Disorder (MH/SUD)] and med/surg benefits will be required to determine parity compliance. Note that these plan/policy terms do not automatically violate the law, but the plan or issuer will need to provide evidence to substantiate compliance. The categories and examples [listed in this document] are not exhaustive and are not a substitute for any regulations or other interpretive guidance issued by the Departments."
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