One of the biggest questions currently outstanding is will the DOL require plan sponsors to annual report their Comparative Analysis to them on an annual basis?
The answer is … we don’t know yet, but some confidential sources have indicated that it is a good likelihood. The DOL has made enforcement of Mental Health and Substance Abuse Parity a top focus beginning February 10th, 2021.
The Department of Labor, Treasury and HHS are tasked with developing a reporting process for the information to be submitted and evaluated for compliance, which is expected by the summer of 2022.
Self-insured plans should take steps now to work with the TPA or carrier to ensure NQTLs for mental health/substance use disorder benefits are in parity with covered medical/surgical benefits.
Stay tuned for more information as it becomes available. Contact us with questions in the meantime.