Who takes care of MHPAEA NQTL Comparative Analysis?
What is an NQTL Comparative Analysis under MHPAEA?
The Mental Health Parity and Addiction Equity Act (MHPAEA) requires that mental health and substance use disorder (MH/SUD) benefits be offered on the same terms as medical/surgical benefits.
An NQTL Comparative Analysis is a detailed review that examines a plan’s non-quantitative treatment limitations (NQTLs)—rules and processes that may affect access to care but aren’t based on dollar amounts or visit counts. Examples of NQTLs include:
•Prior authorization requirements
•Step therapy or fail-first protocols
•Standards for medical necessity determinations
•Network admission criteria
The analysis compares how these rules are applied to MH/SUD services versus medical/surgical services to ensure they are no more restrictive for MH/SUD care.
Why is NQTL Comparative Analysis important?
•Regulatory Compliance: Federal law requires self-funded health plans to be able to demonstrate compliance with MHPAEA. Regulatory agencies (such as the Department of Labor) may request the analysis at any time.
•Employer Responsibility: For self-funded plans, the employer is ultimately responsible for maintaining and producing this analysis, even if a TPA provides supporting data.
•Member Protection: The analysis helps ensure that employees and their families have fair access to MH/SUD services without unnecessary barriers.
•Risk Management: Failure to produce a compliant analysis when requested can result in penalties, corrective actions, and reputational risk.
Does Self Fund Health (SFH) provide NQTL Comparative Analysis?
At this time, our TPA partner, Yuzu, does not provide a Non-Quantitative Treatment Limitation (NQTL) Comparative Analysis. While this may change in the future, it is not currently a service available through Yuzu.
What has SFH done to ensure compliance with MHPAEA requirements?
SFH has designed plans to ensure mental health and substance use disorder (MH/SUD) benefits are treated fairly and equitably, for example.
Specifically:
•Cost Share: MH/SUD services are not subject to higher cost sharing than standard medical/surgical benefits.
•Precertification/Preauthorization: Requirements are no more stringent than for medical/surgical services.
•Outpatient Visits: There are no limits on outpatient MH/SUD visits.
•Prescription Medications: MH/SUD medications are covered at the same level as medical prescriptions.
•Preferred Providers: $0 MH/SUD Preferred Providers are available within a 60-mile radius of members, with networks continuously expanding to meet demand.
•Inpatient Services: MH/SUD inpatient services are covered on the same terms as medical inpatient services.
Who is responsible for NQTL compliance?
For self-funded plans, employers are ultimately responsible for filing and ensuring the accuracy of NQTL Comparative Analyses. While TPAs may provide data to support this in the future, it is rare for them to take on full responsibility for producing these reports.
Are there third-party vendors that can help?
Yes. Although Yuzu does not currently offer this service, we are working to compile a list of reasonably priced vendors who specialize in NQTL Comparative Analysis.
Vendor Name |
Vendor Website |
Costs |
|
|---|---|---|---|
| NQTL Analysis Service | Comparative Analysis Pricing | NQTL Analysis Service | $4,999 per year | |
| The Phia Group | https://www.phiagroup.com/ | ||
| CXC | |||
What is SFH’s long-term plan regarding NQTL support?
We will continue to engage with Yuzu and monitor opportunities to expand service offerings. In the meantime, we are committed to identifying and recommending trusted vendors who can provide this support to our clients. SFH's vendor partners such as our TPA and PBM will be resources who can provide these vendors with data and reports necessary when requested.
RESOURCES: