Full-spectrum Support to Meet Your Plan’s Mental Health Parity Needs

Our Mental Health Parity compliance experts assist insurers, health plans, ERISA-plan sponsors and third-party administrators. We help organizations assess and remediate current NQTL analyses for deficiencies and risks, develop new NQTL analyses, and assist with responding to regulatory audits and annual reporting.

We have the propriety tools and expertise to help develop and assess:

• MHPAEA applicability
• NQTL documentation compliance
• Comparative analysis of NQTL application
• Disclosure compliance
• MHPAEA compliance oversight, auditing, and monitoring plan

The Department of Labor (DOL) is actively auditing plans for Mental Health Parity compliance. Plans may need up to 21 different NQTL Comparative Analysis documents to demonstrate that cost-sharing and treatment limits on mental health or substance abuse services are no more restrictive than those for medical or surgical care.  Click here for 2021 DOL investigations and enforcement actions. In its 2021 audits, the DOL found that virtually none of the NQTL analyses were sufficient to demonstrate compliance.

ATTAC can evaluate and help you prepare Mental Health Parity NQTL Comparative Analyses and test QTLs. We also help plans develop required polices, procedures and NQTL documentation. These documents must be provided to the DOL and CMS upon request when audited.

Quantitative Treatment Limit (QTL) Testing

Financial requirements (copays, deductibles) and QTLs that apply to mental health and substance-use disorder benefits must be no more restrictive than the predominant financial requirements and treatment limitations that apply to substantially all M/S benefits. Testing should be done every time you change plan cost-sharing or benefits.

ATTAC partners with an industry-leading actuarial firm with extensive MHPAEA experience to perform the QTL substantially-all and predominance testing for each plan offered. The QTL testing evaluates whether plan designs meet the financial restrictions and QTL requirements of MHPAEA regulations and provides opportunities for improvement when needed.

Mental Health Parity Proposed Rules: Compliance Just Got More Complex & Costly

Building effective Mental Health Party NQTL comparative analyses has been a challenge from the beginning, and the new proposed regulations will cause most plans to go back to the drawing board to expand and revise their NQTLs.

ATTAC’s Mental Health Parity team has helped plans and issuers of all sizes, including Blues, build or rebuild NQTL analyses to meet compliance requirements.

Non-Quantitative Treatment Limitations (NQTL) Compliance & Testing

We assist with reviewing and documenting each NQTL Comparative Analysis within the six benefit classes defined by regulation. ATTAC guides insurers through each step of identification, documentation, assessment, evaluation, and remediation of all NQTLs for each plan design. This includes reviewing plan features that may or may not be expressed numerically, but would otherwise impact the scope or duration of the benefit.

Partnering with our Mental Health Parity experts can provide your team with a plan to conquer your NQTL needs. Working with ATTAC saves time and resources as the parity documentation requirements tighten and the enforcement landscape evolves.

Establishing an Internal Mental Health Parity Compliance Plan

The requirements and analysis of the NQTLs, QTLs, and other actions needed to comply with MHPAEA and its regulations cause significant risks to health plans. A Mental Health Parity Compliance plan can help prevent, detect, assess, oversee, and mitigate potential noncompliance to avoid enforcement and legal risks.

ATTAC can help your health plan or ASO group establish a MHPAEA compliance plan or enhance your current compliance program to incorporate MHPAEA oversight activities.