The Department of Labor has issued guidance, in the form of "Frequently Asked Questions" regarding the requirement under the 2010 Health Care Reform Legislation to provide a uniform Summary of Benefits and Coverage. The guidance delays the requirement to provide the Summary until the effective date of final regulations. The FAQs state that the final regulations will be issued as soon as possible. The DOL had originally proposed a deadline of March 23, 2012.
The FAQs also answer questions that the DOL has received on how to evaluate whether non-quantitative treatment limitations comply with the Mental Health Parity and Addiction Equity Act of 2008. The guidance provides:
- Prior authorization may not be required for mental health and substance use disorder benefits if it is not required for medical/surgical benefits.
- The prior authorization process for mental health and substance use disorder benefits, including evidentiary standards and alternative strategies, may not be more stringent than it is for medical/surgical benefits.
The FAQs may be accessed on the DOL website at http://www.dol.gov/ebsa/faqs/faq-aca7.html.
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