Warning Signs – Plan Or Policy NQTLs That Require Additional Analysis To Determine Mental Health Parity Compliance

In 2019, the Department of Labor released guidelines regarding the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA) and non-quantitative treatment limitations (NQTLs). The guidelines outlined in this report focus specifically on NQTLs and how to identify provisions that will require inquiry beyond the plan/policy terms in order to determine compliance with mental health parity requirements; the report outlines pre-authorization and pre-service notification requirements; fail-first protocols; probability of improvement; and the required written treatment plan . . .