Benefits BRIEF: Mental Health Parity: NQTL – Comparative Analysis Requirements

The Consolidated Appropriations Act, 2021 (CAA), enacted in December 2020, amended the Mental Health Parity and Addiction Equity Act of 2008 (MPHAEA) to require employers that sponsor self-funded group health plans that cover mental health or substance use disorder benefits to perform a “comparative analysis” of any non-quantitative treatment limitations (NQTLs) effective February 10, 2021. All group health plans are subject to the CAA.
Fully insured plans, however, have relief from this requirement as the insurance carrier has the obligation to perform the comparative analysis, not the employer.

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