Enforcing the Mental Health Parity and Addiction Equity Act (MHPAEA) has now become a priority for the federal government. The Obama Administration has recently turned its attention to the problems of mental health and substance abuse disorders. In late 2015, President Obama issued a presidential memorandum to a number of executive agencies regarding the widespread heroin addiction epidemic. As a result, plans can expect increased enforcement of the MHPAEA and audits of MHPAEA compliance.
The MHPAEA generally requires that there be parity between medical/surgical benefits and mental health/substance abuse benefits in health plans. The regulations are extremely complex and until recently there was very little guidance interpreting the regulations. In June, the DOL/HHS published a checklist of some potentially problematic non-quantitative treatment limitations. Plan sponsors should carefully review the checklist and stay alert for additional developments.