Full-spectrum Support to Meet Your Plan’s Mental Health Parity Needs
Our Mental Health Parity compliance team 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 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.
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 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.
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 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
We will assist you with reviewing and documenting each NQTL Comparative Analysis within the six benefit classes defined by regulation. ATTAC 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 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.
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. Our team has helped plans and issuers of all sizes, including Blues, build or rebuild NQTL analyses to meet compliance requirements.
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.
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.