The Biden administration’s mental health parity rule proposals include a new test that has raised concerns in the health-care industry. This test, known as the “substantially all” test, states that non-quantitative treatment limitations (NQTLs) must be applied equally to mental health benefits as they are to medical and surgical benefits under the Mental Health Parity and Addiction Equity Act.
The proposal has caused fear among health-care providers who commonly use techniques to control costs for employee health plans. NQTLs can include requirements such as prior authorization for care, which may be more stringent for mental health benefits compared to medical and surgical benefits.
The Departments of Health and Human Services, Labor, and the Treasury have highlighted the importance of ensuring that NQTLs are applied equally to mental health benefits to prevent discrimination. This proposal aims to promote parity in coverage for mental health and substance abuse benefits, ensuring that individuals have access to the care they need without facing unnecessary barriers.
Although the proposal is still near-finalized, its implications for the health-care industry are significant. Providers may need to adjust their cost-control techniques to comply with the new standards, potentially leading to changes in how mental health benefits are managed within employee health plans.