Aug 13, 2021
Blue Shield of California has provided a response to Section 203 of the Consolidated Appropriations Act (CAA), Mental Health Parity and Addiction Equity Act (MHPAEA). More detailed information can be found in these Frequently Asked Questions.
Blue Shield has prepared a process document for demonstrating CAA Section 203 compliance. This process document will be applicable for all groups - fully insured and self-funded - for which they administer both medical and surgical (M/S) and mental health and substance use disorder (MH/SUD) benefits.
Blue Shield cannot anticipate the specific information the Department of Labor might request to fully demonstrate compliance with Section 203. For this reason, the Section 203 process document will be provided upon request as needed. Should any of your employer group clients require comparative analysis for MHPAEA, the group or their brokers should contact their Blue Shield representative.
Blue Shield will respond to state regulators as required to demonstrate that the design and operation of fully insured plans filed with the DMHC and CDI are compliant with Section 203.
Their work continues on other parts of the CAA and TCFR as well. While they intend to be compliant with all provisions by their respective deadlines, some outcomes will be ready to share with brokers sooner than others. They will continue to provide updates on their progress.
You can also check the Blue Shield Mandates page on Broker Connection for more information and updates, including mandate summaries and FAQs.
