Apr 25, 2022
The Dept. of Labor (DOL) has an important reporting requirement that applies to all self-funded benefit plans in which employers have had at least 51+ employees during the preceding calendar year. These employers that offer mental health and/or substance abuse benefits must have a comparative analysis performed on their plan benefits.
This is not a requirement of Amwins Connect Administrators, but of the Dept. of Labor under the Mental Health Parity Addiction Equity Act (MHPAEA).
A Reporting Solution for Our Clients
After extensive research on vendors, Amwins is referring clients to NQTL Analysis Service. They will provide the MHPAEA Comparative Analysis to our clients. Once a plan sponsor signs up for their services, Amwins will work closely with NQTL and provide the information that’s needed to complete the analysis. NQTL will provide the results to the plan sponsor once the analysis is complete.
An Overview of the Requirements
Insurance carriers are responsible for the compliance and assessments of Mental Health and/or Substance Abuse benefits for fully insured plans. However, all self-insured benefit plan sponsors/employers will be responsible for the compliance and assessments of these benefits.
The analysis must also be performed on all plan vendors (TPA, PBM, formulary, carve-out programs, care management, etc.).
There is much more to this analysis than just parity of the benefits and/or cost-sharing. The analysis compares non-quantitative limits, which include what the providers are being paid compared to other providers in the area as well as processes, strategies, standards, and other criteria that limit the scope or possibly duration of benefits. Networks, medical management, and PBMs would be included to complete the analysis.
Important to Remember
A Comparative Analysis can be requested at any time by the DOL, the IRS, or plan participants. However, it is the DOL regulation that requires all plan sponsors meeting the criteria above to have this analysis performed and monitored.
If a plan participant or the DOL asks for a copy of the analysis, the plan has 45 days to provide it.
If requested, the plan sponsor must also make the analysis available to the Department of Health & Human Services (HHS) or applicable state authorities.
Replay A Webinar
Amwins Connect Administrators and NQTL hosted five webinars over the past two months on the details of this requirement and its importance. In case you missed it, you can replay the webinar.
If you have any questions, please contact your Self-Funded Account Manager or the Amwins Compliance Department at gbs.compliancedept@amwins.com or kathleen.thompson@amwins.com
