Mental Health Parity Compliance NQTLs and QTLs
ATTAC Consulting Group (ACG) assists insurers, health plans, ERISA plan sponsors and TPAs develop Mental Health Parity Non-Quantitative Treatment Limitations (NQTL) Comparative Analysis along with obtaining Quantitative Treatment Limits (QTLs) testing to demonstrate Mental Health Parity compliance.
Mental Health Parity compliance is required for insurers, self-funded ERISA plans offering healthcare coverage.
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 on hand to demonstrate during an audit 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. The DOL found in their 2021 audits that virtually none of the NQTL analyses were sufficient to demonstrate compliance.
ACG 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 are needed to be able to provide 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 each and every time you change plan cost sharing or benefits.
ACG 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 will evaluate whether the plan designs meet the financial restrictions and QTL requirements of the MHPAEA regulations and provide opportunities for improvement when needed.
Non-Quantitative Treatment Limitations (NQTL) Compliance and Testing
ACG will assist you with reviewing and documenting each NQTL Comparative Analysis within the six benefit classes defined by regulation. ACG supports insurers and ERISA self-funded groups 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 ACG experts with MHPAEA experience can provide your team with a plan to conquer your NQTL needs. Working with ACG saves time and resources as the parity documentation requirements tighten and 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 and ERISA self-funded groups. A MHPAEA Compliance Plan can help plans accurately prevent, detect, assess, oversee, and mitigate potential MHPAEA noncompliance to avoid enforcement and legal risks.
ACG can help your health plan or ASO group establish a MHPAEA compliance plan or enhance your current compliance program to incorporate MHAPEA oversight activities.