JD Supra June 25, 2021
Since the passage of the original mental health parity requirements over two decades ago, mental health parity can be described as riding a porpoise as it dives in and out of the waters of compliance. However, with the passage of the Consolidated Appropriations Act, 2021 and new guidance from the Employee Benefits Security Administration, mental health parity can now be described as riding an endless wave of legal compliance.
New Mental Health Parity Comparative Analysis
Section 203 of the Consolidated Appropriations Act, 2021, Division BB (“CAA”) established new legal compliance standards for nonquantitative treatment limitations (“NQTL”). In general, NQTLs are limitations on mental health and substance abuse benefits that are not numerical in nature. NQTLs include the...