Lexology August 7, 2023
Thompson Hine LLP

On July 25 the U.S. Departments of Treasury, Labor and Health and Human Services (“tri-agencies”) released guidance related to the Mental Health Parity and Addiction Equity Act (MHPAEA). Among other documents, the guidance includes a proposed update to the MHPAEA regulations and a report to Congress summarizing the tri-agencies’ enforcement efforts related to group health plans’ obligations to perform and document non-quantitative treatment limitation (NQTL) analyses.

Although new requirements described in the proposed regulations will not take effect unless and until regulations are finalized, the MHPAEA guidance as a whole provides a wealth of information that employers can and should be addressing now.

Key Takeaways

  • The DOL expects plans to have already performed and documented NQTL analyses. Even if...

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