Helaine Fingold, Lesley Yeung, Kevin Malone, and David Shillcutt, attorneys in the Health Care & Life Sciences practice, co-authored an article in the Journal of Health Care Compliance, titled “Mental Health and Substance Use Disorder Parity Compliance: Navigating New Proactive Documentation Requirements and Shifting Federal Enforcement Priorities.”

Following is an excerpt (see below to download the full version in PDF format):

In the absence of needed guidance with respect to the implementation of recent Congressional amendments to the federal Mental Health Parity and Addiction Equity Act (MHPAEA), stakeholders can gain key insights into the federal enforcement approach on parity from a new set of Frequently Asked Questions (FAQs) issued by the federal Departments of Labor (DOL), Health and Human Services (HHS), and Treasury (collectively, “the Departments”). The new parity documentation requirements, enacted through the Consolidated Appropriations Act, 2021 (CAA) on December 27, 2020, are already in effect as of February 10, 2021. Accordingly, plans and issuers must ensure that they understand and are prepared to provide regulators with documentation of their compliance with parity requirements on at least a small group of specific non-quantitative treatment limits (NQTLs), as the Departments have declined to explicitly exercise their enforcement discretion to provide affected entities with an extended timeline for compliance with the new requirements. ...

Download the PDF: "Mental Health and Substance Use Disorder Parity Compliance"Download
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