Overview
The Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA) was intended to improve access to services for mental health and substance abuse disorders. MHPAEA requires group health plans to ensure that the mental health and substance use disorder benefits they offer are in parity with medical and surgical benefits. Recently, with the passage of the Consolidated Appropriations Act of 2021 (CAA), intentions became codified. The Departments of Labor, Treasury, and Health and Human Services are now required to select, collect, and review comparative analyses from employers that demonstrate their offered health plan’s compliance with MHPAEA regulations. The Department of Labor (DOL) has elevated MHPAEA compliance to a top priority, working with their Employee Benefits Security Administration (EBSA) office to develop a dedicated task force to identify instances of MHPAEA noncompliance. If a health plan is found noncompliant, or if no comparative analysis is produced, the employer may be required to notify all participants in the plan of noncompliance. This could potentially result in lawsuits against the plan. In extreme cases, the plan could be required to re-adjudicate claims that were previously denied.
Lumelight offers multiple solutions to help employers reach MHPAEA compliance. At a base level, a team of expert analysts reviews each self-funded health plan offered and provides a detailed report of potential points of noncompliance. Additionally, we offer a full-service option which requires cooperation with the client’s third-party administrator(s) to obtain claims data in addition to plan documents. After receiving data, our team produces a custom comprehensive report, complete with all required testing and analysis, plus recommendations for bringing any inconsistencies or areas of noncompliance into parity.
Challenge/The Situation
Trinity Industries, Inc. doesn’t take risks with their compliance. When their broker came to them with the new CAA requirement and possibility of a government audit from the DOL, they jumped at the opportunity to get their MHPAEA comparative analysis done. Emily Conner, Trinity’s Benefits Manager, said, “we like to stay ahead of our compliance needs,” especially when reporting to their internal compliance committee annually. When deciding between options for this new service, this team was the obvious choice. Considering cost and services, the audit support was a major deciding factor. Emily explained, “[They] will go back and assist us in an audit at no additional cost.”
Resolution
After receiving Trinity’s plan documents, Lumelight’s expert, dedicated analyst team was eager to turn their proven process into a polished comprehensive MHPAEA Comparative Analysis Report complete with findings and recommendations. Emily was thrilled with the ease of the process. “It was a very easy process,” Emily said; “I wasn’t involved constantly and I appreciate that. My time is stretched thin very often [and] it was helpful to have someone else carrying the bulk of the work.” Our team’s custom comprehensive comparative analysis comes with an easily digestible executive summary and results call to dive into any questions clients may have. “You guys made it really easy on us…overall very thorough, good reporting, good results, and helped us get what we needed to get done!”
Key Takeaways
Working with our team of experts on a MHPAEA Comparative Analysis gives clients a jumpstart on compliance, safeguarding not only their financial and legal interests, but also the overall mental and emotional wellbeing of their employees. Should Trinity Industries be faced with a DOL audit, Emily is confident; “we can say that we did our due diligence. We did our reporting and analysis and had a third-party organization review all of our information—we’re good to go.”
