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DOL Finds No One Has a Compliant Mental Health Parity Comparative Analysis

The DOL recently posted its “2022 MHPAEA Report to Congress”, which highlights the DOL’s recent emphasis on greater MHPAEA enforcement and also discusses the significant resources dedicated to that effort. “MHPAEA” is the acronym for the Mental Health Parity and Addiction Equity Act of 2008; i.e. the mental health and substance use disorder rules that apply to employer-sponsored group health plans. The MHPAEA was amended by the Consolidated Appropriations Act of 2021 to require plans to provide a written comparative analysis of their nonquantitative treatment limitations on mental health and substance use disorder benefits to the DOL upon request. See our prior blog posts on this issue here, here, and here. Between April 9, 2021 and October 31, 2021, the DOL issued 156 letters to plans and issuers requesting comparative analyses: 141 to plans (7 to plans providing fully-insured coverage and 134 to plans providing self-funded coverage) and 15 to issuers. The DOL… Continue Reading

February 2022
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