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ARTICLE · 21 MAY 2021

Agencies Issue FAQs On Required Comparative Analysis Of Nonquantitative Treatment Limitations

Ogletree, Deakins, Nash, Smoak & Stewart
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The Consolidated Appropriations Act (CAA), 2021 had far-reaching effects on employee benefit plans. One of the more onerous changes introduced by the CAA relates to the Mental Health Parity...

United StatesEmployment and HR
Ruth Anne Collins Michels
Ruth Anne Collins Michels
Jessica Kuester
Jessica Kuester
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The Consolidated Appropriations Act (CAA), 2021 had far-reaching effects on employee benefit plans. One of the more onerous changes introduced by the CAA relates to the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA). MHPAEA requires that group health plans offering mental health and substance use disorder benefits (MH/SUD benefits) provide those benefits on no less generous terms than medical and surgical benefits. The rules require various types of comparisons to be made between MH/SUD benefits and medical/surgical benefits to ensure parity within the plan.

The CAA focused on one specific category of comparison: nonquantitative treatment limitations (NQTLs). NQTLs are treatment limits that are not represented by a numerical value. For example, a preauthorization requirement is a NQTL. Under the CAA, employers that sponsor group health plans must document the plans' compliance with the NQTL provisions of MHPAEA. Although the requirement to offer

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