Back in February, three federal agencies issued an interim final rule and sought comments on the implementation of the 2008 Mental Health Parity and Addiction Equity Act (Public Law 110-343). The interim rule outlines “parity” in aggregate lifetime and annual dollar limits, and incorporates new parity standards for health plans.
In response, SHRM submitted comments on May 3. SHRM cautioned the Departments of Health and Human Services, Labor, and the Treasury to “take into account the real world difficulties and expense of applying the rule to multiple plan designs,” when HR practitioners are grappling to understand the numerous implications of the new health care reform law.
SHRM’s comments make several specific recommendations in order to clarify the rule’s requirements, including urging the government to:
- Adopt at least a one-plan-year period of good faith compliance;
- Limit penalties to no more than the cost of the error to insured individuals; and
- Limit parity requirements to those treatment limits that can be quantified such as treatment frequency, visit, and day limits.
To read SHRM’s full comments, click HERE.