Warning Signs- Plan Or Policy Non-Quantitative Treatment Limitations (NQTLs) That Require Additional Analysis To Determine Mental Health Parity Compliance

In this document released in June 2016, the federal Department of Labor highlights health plan structures that could indicate that the plan violates the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA) by imposing non-quantifiable treatment limitations (NQTLs) on coverage or access to behavioral health benefits that are not imposed on medical or surgical benefits. MHPAEA prohibits both quantifiable treatment limitations—such as the number of visits or use of different cost sharing—and NQTLs, which are generally limits on the scope or duration of benefits for treatment that are not expressed numerically, such as medical management . . .