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Health & Welfare Plans Newsletter

April 2, 2021


[Official Guidance]

Text of Agency FAQs, Part 45: Mental Health and Substance Use Disorder Parity Implementation and the Consolidated Appropriations Act, 2021 (PDF)

Section 203 of Title II of Division BB of the Appropriations Act amended MHPAEA, in part, by expressly requiring group health plans and health insurance issuers offering group or individual health insurance coverage that offer both medical/surgical benefits and MH/SUD benefits and that impose NQTLs on MH/SUD benefits to perform and document their comparative analyses of the design and application of NQTLs.  MORE >>

  1. When must plans and issuers make available their NQTL comparative analyses, as required by the Appropriations Act?
  2. What information must plans and issuers make available in response to the Departments' requests for documentation of their comparative analyses?
  3. What are examples of reasons why the Departments might conclude that documentation of comparative analyses of NQTLs is insufficiently specific and detailed?
  4. In addition to documentation of the comparative analyses, what types of documents should plans and issuers be prepared to make available to the Departments to support the analysis and conclusions reached in their comparative analyses of NQTLs?
  5. What actions will the Departments take if they determine that a plan or issuer has not submitted sufficient information to review comparative analyses of the design and application of NQTLs, or if the Departments conduct a review and determine that a plan or issuer is not in compliance with MHPAEA?
  6. May a participant, beneficiary, or enrollee (or their authorized representative), or state regulator request an NQTL analysis?
  7. Will the Departments issue additional guidance on requirements that were added to MHPAEA by the Appropriations Act?
  8. Are there specific NQTLs that the Departments intend to focus on when requesting comparative analyses from plans and issuers for purposes of review in accordance with the requirements of the Appropriations Act?
  9. Who can I contact if I have additional questions about the MHPAEA amendments included in the Appropriations Act that apply to group health plans and health insurance issuers?

U.S. Department of Labor [DOL]; U.S. Department of Health and Human Services [HHS]; and U.S. Treasury Department

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