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Mental Health Parity Compliance & Testing – MHPAEA


Mental Health Parity Compliance – NQTLs and QTLs

ATTAC Consulting Group (ACG) assists insurers, health plans, ERISA plan sponsors and TPAs with Mental Health Parity NQTL compliance and QTL testing.  ACG guides NQTL documentation development and MHPAEA Compliance Programs.  Contact ACG about Mental Health Parity Compliance

Mental Health Parity is required for insurers, self-funded ERISA plans offering group or individual health coverage as well as Medicaid plans under the MHPAEA regulations.

Plans must ensure that cost sharing and treatment limits on mental health or substance abuse services are no more restrictive than those for medical and surgical care.   CMS and the Department of Labor (DOL) are actively auditing plans for Mental Health Parity compliance; click here to review investigations and enforcement actions.  States test for Mental Health Parity as well.

ACG can test Mental Health Parity Non-Quantitative Treatment Limitations (NQTL) and Quantitative Treatment Limits (QTL).  We also help plans develop required polices, procedures and NQTL documentation. These documents are needed to operate a compliant program and to provide to CMS and the DOL upon request when audited.  Connect Now with ACG’s Mental Health Parity Experts.

Quantitative Treatment Limit (QTL) Testing

Financial requirements (copays, deductibles, etc.) and QTLs that apply to MH and SUD 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

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301 E. Liberty Street, Suite 605
Ann Arbor, MI 48104
T. (734) 214-2990