Department of Labor Releases Interim Final Regulations for the Mental Health Parity and Addiction Act of 2008
The Interim Final Regulations were published on February 3, 2010. Click here to view the regulations.
MHPAEA expands upon MPHA by imposing additional requirements on group health plans related to both mental health and substance use disorder benefits. These regulations prohibit group health plans from applying different financial requirements or treatment limitations for mental heath or substance use disorder benefits than those applied for general medical or surgical benefits.
Click here to read an overview from the National Alliance on Mental Illness, a long-time advocate for mental health parity.Reminder: Part D Annual Disclosure to CMS Due by March 1, 2010
The Centers for Medicare and Medicaid Services (CMS) requires employers to annually report via its Web site the credibility/non-credibility status of sponsored plans. This filing has taken place every year since Part D was first introduced and the process is the same this year.
The following is a link to the CMS Web site with more details:
Creditable Coverage Disclosure to CMS
The required online disclosure form is here:
Disclosure to CMS form
The online form requires you to provide some specific information on your plan(s) within 60 days after the beginning of the plan date. Therefore, a plan sponsor with a January 1 effective date needs to make this filing before March 1, 2010. This is a relatively easy process and will likely take only a short amount of time to complete (10-15 minutes).
Medicare Part D will continue to have notice and reporting requirements that will need to be addressed each year. BSG will continue to monitor all of the Part D developments and will continue to update our clients as we learn anything new. If you are a BSG client and need any assistance, please feel free to call Sue Thomas, Director of Analytical Services-Contracts & Compliance at 262-446-5993.
Model Employer Children's Health Insurance Program Notice
On February 4, 2009, President Obama signed the Children's Health Insurance Program Reauthorization Act (CHIPRA) of 2009. CHIPRA includes a requirement that the Department of Labor and Health and Human Services develop a model notice for employers to use to inform employees of potential opportunities currently available in the State in which the employee resides for group health plan premium assistance under Medicaid and the Children's Health Insurance Program (CHIP). The Department of Labor was required to provide the model notice to employers within one year of CHIPRA's enactment.
Through a notice in the February 4, 2010 FEDERAL REGISTER, the Department's Employee Benefits Security Administration (EBSA) announces the availability of the Model Employer CHIP Notice. The notice provided the "form and content of notice" as well as the "timing and delivery of the notice" while outlining the requirements for addition of state-specific information.
The model Employer CHIP Notice is now available in an electronic format.
