Will NQTL Require Reporting?

One of the biggest questions currently outstanding is will the DOL require plan sponsors to annual report their Comparative Analysis to them on an annual basis? The answer is … we don’t know yet, but some confidential sources have indicated that it is a good likelihood. The DOL has made enforcement of Mental Health and Substance Abuse Parity a top focus beginning February 10th, 2021. 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.