Lexology September 19, 2024
On September 9, 2024, the Departments of the Treasury, Labor and Health and Human Services (collectively, the “Departments”) released final rules implementing the nonquantitative treatment limitation (“NQTL”) comparative analyses requirements under the Mental Health Parity and Addiction Equity Act of 2008 (“MHPAEA”), in accordance with the amendments made to the law in 2021. These requirements prohibit group health plans and health insurance issuers from using NQTLs that place greater restrictions on access to mental health and substance use disorder benefits as compared to medical and surgical benefits. The regulations, which were finalized a little over a year after the Departments initially proposed them (see our prior alert here), seek to reinforce the obligations of group health plans and health insurance...
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