DOL's New Charge - Understanding and Administering the Employer's Mental Health Parity Obligations
As reported in the DOL's first MHPAEA enforcement report to Congress in 2022, the DOL's Employee Benefits Security Administration offered details respecting hundreds of private employer MHPAEA compliance audits conducted by the agency in 2020. Disturbingly, not one employer audited was able to demonstrate substantive compliance with the law's requirements. This program is designed to provide intermediate and advanced HR practitioners with a practical and actionable survey of MHPAEA's requirements. Participants will survey compliant plan design schematics respecting both Quantitative Treatment Limitations ('QTL's') and Non-quantitative Treatment Limitations ('NQTL's'). Participants will also review requirements related to the employer's NQTL comparative analysis obligations. Finally, program participants will review the plan-level participant and beneficiary directed responsive communication requirements for employers responding MHPAEA related claims and coverage issues.
Learning Objectives:
- Understand and apply the concepts underlying MHPAEA, including, without limitation, mental health parity, substance use disorder parity, classification of plan-level benefits, identification of prohibited QTL's and NQTL's within a specific benefit plan; and, specific benefit testing rules;
- Learn to identify and interpret regulatory compliance obligations respecting the plan-level administration of QTL's and NQTL's, both as written and as in actual operation of the underlying benefit plan;
- Survey and apply the components of the DOL's required comparative analysis of NQTL's across the six (6) permitted classifications of plan-level benefits;
- Review and understand MHPAEA's required participant and beneficiary communication requirements related to plan-level covered services and benefit claims arising in the mental health and substance use disorder context; and,
- Review and understand the enforcement protocols and various interdiction levers available to the DOL, HHS and state-level insurance and regulatory bodies, respecting MHPAEA compliance obligations for the employer benefit plan sponsor.
In-person session offerings are on a first-come, first-served basis.
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Jason Nathaniel Sheffield
Jason Sheffield is BRPs National Director of Compliance for the Baldwin Regulatory Compliance Collaborative. He oversees the ongoing evolution of our firm's national compliance operations. Jason develops, designs and implements educational programming and compliance assuredness services by creating timely and relevant solutions designed for the benefit of our clients and colleagues, our industry partners, and the general benefits community. Jason has practiced employee benefits law and consulting for nearly two decades, representing individual, corporate, and tribal interests at the local, state, and federal levels. He has advised clients and provided representative services before administrative agencies such as the DOL, the IRS, CMS, OCR, several state-level treasury authorities, and others. He has experience with both qualified and non-qualified retirement plans, executive compensation matters, and extensive experience respecting health and welfare plan matters. Jason received his undergraduate degree from Georgia State University (magna cum laude) and his Juris Doctor from Western New England College School of Law. He is admitted to the State Bar of Georgia.