The Maryland Parity Project was proud to host three presenters from the US DOL Employee Benefit Security Administration on June 11th. The presenters gave a comprehensive overview of the current federal mental health parity regulations, using concrete examples to make the regulations understandable.
Presenters did their best to answer questions about insurers compliance with non quantitative treatment limitations (NQTL), current investigations at DOL, and difficulties getting insurers to disclose their medical management procedures and criteria. Presenters were also open to taking comments back to others working on final regulations with the possibility of future release of more subregulatory guidance in the form of FAQs. Participants offered comments on varied issues:
- difficulty getting insurers to disclose information
- the possibility of unintended loopholes in the NQTL regulations
- the feasibility of requiring insurers to perform parity analyses of their benefit design and submit them to DOL rather than wait to be prompted by a complaint
- difficulty for insurers to comply with NQTL regulations without some quantitative measures to use for analysis purposes
Of course, presenters were unable to give participants any idea of when the final rule would be released or specifics of current investigations underway or outcomes of past investigations. Overall this was a great event that set the stage for the upcoming DC Metro Congressional Forum and established a dialogue where stakeholders are able to forward other comments, questions or examples of issues not addressed by the current regulations. If you have comments or questions, please Contact Us.