Compliance Alert - Mental Health Parity Regulations (back)
6/29/2010
Earlier this year, interim final regulations (Interim Regs) were issued by the Department of Treasury, Labor, and Health and Human Services, that provided much needed detail to assist plans with complying with the Mental Health Parity and Addiction Equity Act of 2008 (“MHPAEA”) or otherwise known as the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008. Compliance with the interim final regs is required by the first day of the first plan on or after July 1, 2010. (If the plan is governed by a Collective Bargaining Agreement (CBA), there may be exceptions to this effective date.)
As you are already aware, MHPAEA provides that if a group health plan offers mental health and/or substance abuse benefits, they must offer equivalent benefits for mental illness and substance abuse disorders as they do for substantially all medical/surgical benefits. It was unclear prior to the regulations how a plan determines “substantially all.” These regulations now provide a different alternative that groups may use to comply with the regulations. These alternatives include:
• Simply selecting the least restrictive financial limitations among each of six benefit classifications and applying them to mental health/substance abuse benefits within those same classifications.
• Amending all medical/surgical and mental health/substance abuse benefits to apply the same financial limitations to all benefits within each classification.
• Completing a comprehensive analysis of all financial limitations on all plan benefits on a classification-by-classification basis.
In addition, the regulations provide information on how prescription drug coverage and Employee Assistance Programs (EAPs) are impacted by MHPAEA. The Interim Regs also address the two required disclosures under MHPAEA.
Meritain Health has developed the attached FAQs to help clients understand and comply with the Interim Regs. For additional information, click here.
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