According to the Bulletin, employers need to:
- Review plan designs to assess whether the parity provisions are met within each of the six classifications (inpatient in-network, inpatient out-of-network, outpatient in-network, outpatient out-of-network, emergency care, and prescription drugs);
- Project expected plan payments for medical claims and perform calculations to determine the predominant financial requirement or treatment limit for medical benefits;
- Evaluate all medical management tools used for medical, mental health and substance-use disorder benefits and determine whether they meet the parity requirements;
- Weigh the pros and cons of making plan design and pricing changes and determine the overall financial impact on the plan;
- Determine the impact of the law on a plan’s managed mental health network;
- Assess how mental health and substance-use-disorder benefits can continue to be delivered cost effectively;
- Amend summary plan descriptions and other plan documents to reflect any plan design changes; and
- Communicate coverage changes to plan participants.
The U.S. Departments of Labor, Health and Human Services (HHS), and the Treasury last month jointly issued new rules prohibiting group health insurance plans — typically offered by employers — from restricting access to care by limiting benefits and requiring higher patient costs than those that apply to general medical or surgical benefits (see Treasury, HHS Issue New Rules on Mental Health Parity). The rules implement the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA).
The Segal Bulletin is here.