JD Supra September 21, 2023
The Consolidated Appropriations Act, 2021 (CAA) added a requirement for health plans to document their compliance with nonquantitative treatment limitations (NQTLs) under the Mental Health Parity and Addiction Equity Act (MHPAEA). NQTLs are non-dollar or non-numerical limits, such as medical necessity or prior authorization requirements, standards for in-network provider admission, formulary design, step-therapy protocols, etc. MHPAEA generally requires that NQTLs applicable to mental health and substance use disorder (MH/SUD) benefits are comparable to and no more stringent than those applied to medical and surgical benefits. For additional information about MHPAEA, the CAA’s written NQTL analysis requirement, and additional guidance on this matter since the CAA, refer to Foley’s prior articles on these topics, available here and here.
While the requirement...
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