Lexology August 2, 2023
On July 25, 2023, the Departments of the Treasury (Treasury), Labor (DOL), and Health and Human Services (HHS) (collectively, the Departments) proposed rules that would implement amendments made to the Mental Health Parity and Addiction Equity Act (MHPAEA) in 2021. The much-anticipated guidance is intended to provide clarity for group health plans and health insurance issuers for how to comply with new MHPAEA requirements to perform and document comparative analyses of the design and application of non-quantitative treatment limitations (NQTLs)1 in order to assess the impact of an NQTL on access to mental health and substance use disorder benefits as compared to medical or surgical benefits. Additionally, the proposed rules would amend existing NQTL standards to prevent plans and issuers...
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