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Compliance Update - Mental Health Parity

We are writing to provide an update on our previous communication regarding the new mental health parity requirements under the Consolidated Appropriations Act, 2021.

As we previously shared, MedCost is working to perform and document a comparative analysis on nonquantitative treatment limitations (NQTL) for Mental Health or Substance Use Disorder (MHSUD) benefits. Over the past few months, we have conducted a comprehensive review of MedCost’s products that impose NQTLs. This includes, for example, Utilization Review, Case Management, MedCost and National Networks, the Behavioral Health Solution, our standardized plan language, and pharmacy benefit management services purchased through MedCost. We have also reviewed applicable policy and procedure documents and obtained relevant information from our vendors that provide services in this space. We are also reviewing and updating relevant MedCost policies and procedures to help streamline these analyses. 

We are consolidating this information into analyses that our clients will be able to use to document compliance with this new law. As a reminder, MedCost’s analyses will be limited to products purchased through MedCost. Some plans utilize non-MedCost products and service providers that impose NQTLs. Common examples include behavioral health management programs, networks provided by individual health systems (sometimes referred to as ‘domestic’ networks), specialty pharmacy programs, and pharmacy benefit management services (when purchased through a broker or direct contract with the plan). If your plan utilizes non-MedCost products or service providers, you should contact the relevant vendor to obtain a NQTL analysis for their product(s) to ensure compliance with this new requirement. 

We expect to make the MedCost product analyses available to our clients in the fourth quarter of 2021. This timing will allow us to perform a thorough review for all of our clients.

In the unlikely event that you receive a request for an NQTL analysis before then, please contact your MedCost Account Manager for assistance.