Partner Sage Fattahian and associate Lindsay Goodman authored an article in Practical Guidance on key takeaways of the 2022 Report to Congress from the US Departments of Labor, Health and Human Services, and Treasury. Under the Mental Health Parity and Addiction Equity Act, the report requires these agencies to provide comparative analyses and documentation demonstrating compliance for group health plans that offer medical/surgical and mental health/substance use disorder coverage imposing non-quantitative treatment limitations.
“The top four non-quantitative treatment limitations (NQTLs) for which the [Employee Benefits Security Administration] requested a comparative analysis include (1) preauthorization or precertification requirements; (2) network provider admission standards; (3) concurrent care review; and (4) limitations on applied behavior analysis or treatment for autism spectrum disorder,” Sage and Lindsay write.