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DOL Updates Health Plan Self-Compliance Tools
By: Jason Lacey

The DOL has updated the self-compliance tools it makes available to group health plans to include a new checklist relating to health care reform.

The health care reform checklist goes through a series of detailed questions that will help a plan sponsor confirm that it is in compliance with the key group market reforms, such as coverage of dependent children to age 26 and cost-free preventive care. There are particularly extensive provisions addressing grandfathered plan status and the SBC requirement.

A second checklist relates to the HIPAA portability provisions and related requirements for group health plans, including mental health parity. (See related prior coverage here.)

Plan sponsors or administrators would be well-advised to go through these lists once a year or so to determine if there are any areas in which their plans are deficient. It is always easier to correct problems that are identified before the DOL finds them.

DOL Updates Self-Compliance Tool for Mental Health Parity and Addiction Equity Act of 2008
By: Jason Lacey

The Department of Labor (DOL) has updated its Self-Compliance Tool for Part 7 of ERISA: HIPAA and Other Health Care-Related Provisions to address the requirements of the Mental Health Parity and Addiction Equity Act of 2008. The tool provides a detailed checklist of various requirements that group health plans must comply with, and will be useful to employers and plan administrators wanting to confirm their plans are up to speed. The Mental Health Parity provisions are addressed in Part II of the checklist.

DOL Releases FAQs on Mental Health Parity Requirements
By: Jason Lacey

The U.S. Department of Labor (DOL) has released a set of FAQs on the obligations of group health plans with respect to mental health and substance abuse benefits. The FAQs specifically discuss changes made by the Mental Health Parity and Addiction Equity Act of 2008.

The FAQs serve as a good reminder about these rules. Among other things, group health plans are prohibited from imposing visit limits on mental health and substance abuse benefits that are more restrictive than visit limits on medical/surgical benefits. Plans also may not use a separate deductible for mental health and substance abuse benefits and may not operate in a way that treats mental health and substance abuse benefits less favorably than other benefits.


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Don Berner, the Labor Law, OSHA, & Immigration Law Guy
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Boyd Byers, the General Employment Law Guy
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Jason Lacey, the Employee Benefits Guy
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