On September 23, 2024, the Department of Labor, Health and Human Services, and Treasury collectively published the Requirements Related to the Mental Health Parity and Addiction Equity Act (MHPAEA) Final Rules. These Final Rules include plan coverage clarifications as well as documentation requirements and timeframes for preparing non-quantitative treatment limitations (NQTLs) comparative analyses now mandated under MHPAEA, as amended by the Consolidated Appropriations Act of 2021 – and responding to Agency Mental Health Parity audits.
The Final Rules also add protections for plan participants against restrictive mental health and substance use disorder (MH/SUD) benefits NQTLs – as compared to NQTLs for medical/surgical (Med/Surg) benefits. The Final Rules are lengthy (over 160 pages in the Federal Register) and quite complicated. Some of the Final Rule’s provisions are effective in 2025 and some in 2026.
MedBen has prepared a detailed summary of these requirements, and the actions plan sponsors are required to take to be in compliance with the Final Rules. Clients may request a copy of this summary from their Account Management team.
For more information about the Final Rules, how they may apply to your group health plan, and the actions necessary to comply, please contact Director of Compliance & Human Resources Erin Kelly at 740-522-7368 or President & Chief Operating Officer Caroline Fraker at 740-522-7386.