What Is Required of Plan Sponsors?
The DOL has issued guidance about what type of analysis and documentation must be performed by plan sponsors. You can access this information guidance here.
The DOL states that the comparative analysis must contain a “detailed, written, and reasoned” explanation of the basis for a plan’s conclusion that NQTLs comply with the parity law.
Generalized statements about compliance without detailed supporting explanations and evidence is not sufficient.
Translation: The DOL was very disappointed by the information they received by plan sponsors during audits in terms of their compliance with MHPAEA. As we all know, there is a huge focus on mental health and substance abuse in our county. The goal of this additional requirement is to bring plans into compliance with rules that truthfully have been around since 2008.