On April 7, 2021, the Department of Labor (DOL) issued FAQs and model notices for the COBRA premium assistance provisions of the American Rescue Plan Act (ARPA).
The Consolidated Appropriations Act, 2021 (CAA) amended the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA) to provide additional protections. On April 2, 2021, the DOL, Health and Human Services (HHS) and the Treasury jointly issued FAQs to clarify these amendments.
In particular, the CAA requires group health plans and health insurance issuers to conduct comparative analyses of the nonquantitative treatment limitations (NQTLs) used for medical and surgical benefits as compared to mental health and substance use disorder (MH/SUD) benefits.
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