Lexology October 4, 2023
The U.S. Department of Labor (DOL), the U.S. Department of Health and Human Services (HHS), and the U.S. Department of Treasury have issued their second MHPAEA Comparative Analysis Report to Congress. This report is a requirement of the Consolidated Appropriations Act, 2021 (CAA, 2021) and the Mental Health Parity and Addiction Equity Act (MHPAEA).
Under the CAA, 2021, health plans and insurers imposing nonquantitative treatment limitations (NQTLs) on benefits for mental health or substance use disorder (MH/SUD) treatment must complete comparative reports of the design and application of their NQTLs. They also must annually report those results to Congress.
The congressional report noted common deficiencies in the mandatory comparative analysis reports from health plans and insurers that were required to...
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