NQTL Reporting

The DOL has made enforcement of Mental Health and Substance Abuse Parity a top focus beginning February 10th, 2021. This has many implications on employer sponsored health plans and new documentation requirements.

What is a NQTL?

Non-Quantified Treatment Limitations

By now you may or may not have heard of Non-Quantitative Treatment Limitations (NQTLs). NQTLS are non-numerical limits on the scope or duration of benefits for treatment offered by employers to their employees.

What is this?

You might be wondering what this is all about. Simply put, when the DOL has performed audits of compliance with the Mental Health Parity and Addiction Equity Act (MHPAEA), they were less than pleased with the results. Often the DOL would find plans that meet compliance requirements on the surface but once they looked more in-depth they would find that these plans are not in true parity in the overall operations of how they are work for members.

The DOL has listed MHPAEA as a top focus for enforcement. For right now, employers are not required to automatically report to the DOL with their comparative analysis but that is likely to change.

The Department of Labor, Treasury and HHS are tasked with developing a reporting process for the information to be submitted and evaluated for compliance, which is expected by the summer of 2022.

Self-insured plans should take steps now to work with the TPA or carrier to ensure NQTLs for mental health/substance use disorder benefits are in parity with covered medical/surgical benefits.

Stay tuned for more information as it becomes available. Contact us with questions in the meantime.