News & Analysis as of

MHPAEA Consolidated Appropriations Act (CAA)

Foley & Lardner LLP

Final Mental Health Parity Rules – Top Five Changes to the Status Quo

Foley & Lardner LLP on

The Mental Health Parity and Addiction Equity Act and its implementing regulations and guidance (MHPAEA) prohibit health insurance policies and group health plans that cover mental health and substance use disorder (MH/SUD)...more

Epstein Becker & Green

Three Things That Employer Health Plan Sponsors Should Do When the New MHPAEA Rules Are Published

Epstein Becker & Green on

The U.S. Departments of Labor (DOL), Health and Human Services, and the Treasury (collectively, the “Tri-Departments”) published a Notice of Proposed Rulemaking (NPRM) on August 3, 2023, to propose new regulations for the...more

McDermott Will & Emery

Six Wishes for the Forthcoming Final Regulations Under MHPAEA

McDermott Will & Emery on

On July 1, 2024, the US Department of Labor (DOL) submitted final regulations to the Congressional Budget Office (CBO), implementing the Mental Health Parity and Addiction Equity Act (MHPAEA) as most recently amended by the...more

Alston & Bird

Year-End Health Benefits Roundup 2023

Alston & Bird on

It was a lively year for health benefits. Our Employee Benefits & Executive Compensation Group unpacks 2023, from the end of the COVID-19 emergencies to the much-anticipated Mental Health Parity and Addiction Equity Act...more

Snell & Wilmer

2023 End-of-Year Plan Sponsor “To Do” Lists (Part 1) Health and Welfare

Snell & Wilmer on

We are pleased to present our annual End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate Employee Benefits Updates. This Part 1 covers year-end health and welfare plan issues....more

Holland & Hart - The Benefits Dial

The Time Has Come, A Fact’s A Fact: Consider Adding a Welfare Plan Committee

The time may have come to add a welfare plan committee to your company’s governance of employee benefit plans. New legal obligations and other developments impose fiduciary risks for welfare plans similar to what already...more

Foley & Lardner LLP

Action Steps Health Plans Should Take Now In Response To New DOL Guidance on Mental Health Parity

Foley & Lardner LLP on

The Consolidated Appropriations Act, 2021 (CAA) added a requirement for health plans to document their compliance with nonquantitative treatment limitations (NQTLs) under the Mental Health Parity and Addiction Equity Act...more

Keating Muething & Klekamp PLL

Benefits Monthly Minute - August 2023

The August Monthly Minute presents Part II of our mental health parity update and provides highlights of the latest report to Congress on NQTL comparative analyses. While service providers lead the way through mental health...more

Seyfarth Shaw LLP

Mental Health Compliance Report Issued to Congress Spoiler Alert – Plans All Fail

Seyfarth Shaw LLP on

Seyfarth Synopsis: The Mental Health Parity and Addiction Equity Act (MHPAEA) requires group health plans and insurers to cover treatments for mental health and substance use disorders in a manner that is equitable to the...more

Holland & Hart - The Benefits Dial

Better Hide the Wine … Employer Considerations as the DOL Doubles Down on Mental Health Parity Compliance in New Proposed...

The Department of Labor (DOL), the Department of Health and Human Services (HHS), and the Department of Treasury (collectively, the Departments) recently issued proposed Mental Health Parity and Addiction Equity Act (MHPAEA)...more

King & Spalding

HHS, the Department of Labor, and the Department of the Treasury Release Proposed Rules and a Report to Congress regarding Mental...

King & Spalding on

On July 25, 2023, HHS, the Department of Labor, and the Department of the Treasury (the Departments) issued proposed rules (Proposed Rules) and other information regarding health plan and issuer compliance with mental health...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Proposed Rules Push Mental Health Parity Up Benefit Priority List

Now you know. It could not be any clearer to employers that compliance with the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA) will be a—maybe the—top health and welfare benefit priority for federal...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Mental Health Parity Compliance Remains a Key Focus for Federal Agencies

On July 25, 2023, the U.S. Department of Labor (DOL), the U.S. Department of Health and Human Services (HHS), and the U.S. Department of the Treasury released their annual report to the U.S. Congress regarding group health...more

Manatt, Phelps & Phillips, LLP

First Look at Proposed New Federal Mental Health Parity Rules

Last week, the departments of the Treasury, Labor and Health and Human Services (collectively, the Departments) published long-awaited proposed regulations intended to clarify and improve compliance with the federal mental...more

Jackson Lewis P.C.

What Employers Need to Know about the Mental Health Parity Proposed Regulations

Jackson Lewis P.C. on

On July 25, 2023, the tri-agencies of the Departments of Treasury, Labor, and Health and Human Services (the Departments) issued a compendium of guidance designed to facilitate compliance with the Nonquantitative Treatment...more

Faegre Drinker Biddle & Reath LLP

DOL Issues Long Awaited Mental Health Parity Guidance

Plan sponsors, insurers, and third-party administrators should pay close attention to the new guidance to facilitate health plan compliance with complex nonquantitative treatment limitation comparative analyses requirements....more

Woodruff Sawyer

Compliance Alert: CAA, 2023 Eliminates MHPAEA Exemption for Self-Funded Non-Federal Governmental Health Plans

Woodruff Sawyer on

On December 29, 2022, the President signed the Consolidated Appropriations Act, 2023 (“CAA, 2023”), into law. The CAA, 2023, which is largely a bipartisan spending bill, sunsets provisions of the Public Health Service Act...more

Ballard Spahr LLP

Reviewing the Welfare Plan Rules Under the Consolidated Appropriations Act, 2021

Ballard Spahr LLP on

Summary - The Consolidated Appropriations Act, 2021, (CAA) and transparency regulations introduced major changes to health benefit plans. These changes continue to evolve with some requirements just now taking effect....more

Snell & Wilmer

2022 End of Year Plan Sponsor “To Do” List (Part 1) Health and Welfare

Snell & Wilmer on

We are pleased to present our annual End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate Employee Benefits Updates. This Part 1 covers year-end health and welfare plan issues....more

Rivkin Radler LLP

Mental Health Parity – After Years of Failure to Comply, Enforcement is Underway!

Rivkin Radler LLP on

Regulators are now better armed to cite and fine health plans that are not complying with the Mental Health Parity and Addiction Equity Act (MHPAEA) of 2008. A recent report to Congress highlights the enforcement work to date...more

Verrill

DOL Signals Heightened Enforcement of Non-Quantitative Treatment Limitation Requirements

Verrill on

Introduction. When the U.S. Department of Labor issued its biennial 2022 Mental Health Parity and Addiction Equity Act (“MHPAEA”) Report to Congress earlier this year, it outlined significant noncompliance by health plans....more

Foley & Lardner LLP

Behavioral Health Trends for 2022

Foley & Lardner LLP on

Over the last two years, behavioral health (BH) has been one of the biggest growth areas in the health care ecosystem, fueled by the Public Health Emergency (PHE) but in many ways an ignored, overlooked, understaffed, and...more

Verrill

Deciphering First Circuit’s Thirty-page Primer on NQTL Analysis and ERISA Information Requests

Verrill on

The widely publicized 2022 Report to Congress regarding the Mental Health Parity and Addiction Equity Act (“Parity Act”) forewarned greater enforcement efforts by the Department of Labor and highlighted suspected deficiencies...more

Mintz - Employment Viewpoints

Health Plan Transparency and the Case for Welfare Plan Fiduciary Committees

The Consolidated Appropriations Act, 2021 (the “Act”) adopted a series of transparency requirements that apply to employer-sponsored group health plans. These transparency rules impose a series of new and complex obligations...more

Foley & Lardner LLP

Health Plans’ Prior Authorization Rules are under Scrutiny by the DOL for Mental Health Parity Compliance – See the DOL’s Top Five...

Foley & Lardner LLP on

On January 25, 2022, the U.S. Departments of Labor (“DOL”), Treasury, and Health and Human Services (the “Departments”) provided a report (the “Report”) on Mental Health Parity and Addiction Equity Act (“MHPAEA”) compliance...more

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