Pre-authorization procedures, plan disclosures and geographical restrictions are just a few features group health plans will need to re-examine by the time the recently finalized mental health parity rules take effect. For calendar-year plans, this means Jan. 1, 2015 — less than a year away.
The interaction of the Mental Health Parity and Addiction Equity Act and the Affordable Care Act is another wrinkle. By requiring behavioral health coverage as an “essential health benefit,” the ACA will make more plans subject to MHPAEA, the U.S. Departments of Labor, Health and Human Services and the Treasury acknowledged in recent guidance.
The final MHPAEA rules issued in November also codified guidance that had been issued since the interim version came out in 2010. For example, outpatient services may be subdivided into office visits and other services when determining whether the parity requirements are met, but subclassifying generalists and specialists is prohibited.
The final rules also subject intermediate levels of care, such as residential treatment, to the MHPAEA parity analysis, which generally prohibits health plans that offer mental health or “substance use disorder” benefits from applying more restrictive financial or treatment limits than they apply to medical/surgical benefits.
The MHPAEA rules’ full implications for plan design and administration will be detailed by nationally known benefits attorney Mark L. Stember, contributing editor to the Employer’s Guide to HIPAA Compliance, in a Feb. 27 webinar presented by Thompson Interactive.