WTF Is This Bull Shit!

The Departments (DOL, HHS and Treasury) Require Plans To Show Their Work ASAP!

Effective February 10, 2021, and pursuant to the Consolidated Appropriations Act, 2021 (CAA), group health plans are required to perform and document comparative analyses, specifically regarding the design and application of Non-Quantitative Treatment Limitations (NQTLs). Plans must act now to “show their work” as to how they comply with this new regulatory requirement.

Necessary comparative analysis components:

  • Group health plans must disclose their comparative analysis, upon request
  • A “detailed, written, and reasoned explanation” of the specific plan terms and practices involved
  • The bases for the plan’s determination that an NQTL is compliant with the Mental Health Parity Addition Equity Act of 2008 (MHPAEA)

Act immediately since failure to provide a “sufficient” comparative analysis, as determined by the Departments, will result in consequences for the plan, such as (but not limited to) informing all individuals on the plan that coverage is noncompliant with MHPAEA and sharing the findings of noncompliance with the state where the plan is located.

To ensure compliance with this regulation, plans must prepare this comparative analysis immediately. The Phia Group has multiple options for plans and administrators to assist with the comparative analysis process. Please contact us at for more information.


WTF is this bullshit?

EDITOR’S NOTE: Love this response. Shows client clearly shares our philosophy