MHPAEA Addendum to Administrative Services Agreement
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Sets forth obligations of Alliant Health (the Company) and Plan Sponsor to comply with the Mental Health Parity and Addiction Equity Act (MHPAEA), including provision of comparative analysis information, fiduciary certification support, and cooperation for audits; applies to the Administrative Services Agreement between the Company and a Plan Sponsor.
No material clinical or coverage changes in this revision.
Key Definitions
Company and Plan Sponsor Obligations
Provide full comparative analysis materials to support Plan Sponsor compliance
Company will provide Plan Sponsor with comprehensive comparative analysis materials necessary for the Plan Sponsor to maintain and document a current MHPAEA comparative analysis. Materials include: clear descriptions of each specific NQTL, plan terms and policies utilized; identification of which benefits are MH/SUD versus medical/surgical and which benefits the NQTL applies to; factors, evidentiary standards/sources, strategies, or processes considered in design or application; explanations of weighting of factors and evaluation of specific data used; any quantitative definitions and supporting sources; explanations of any variation in application between MH/SUD and medical/surgical and the processes/factors for establishing such variation; descriptions of decision(s), decisionmaker(s), timing, and decisionmaker qualifications when administration hinges on specific decisions; descriptions of experts' qualifications when relied upon; proposed findings and conclusions regarding comparability and relative stringency (as applied and written) with citations to evidence and analysis results; and dates and names/titles/positions of persons who performed or participated in the analyses.
- Clear description of each specific NQTL, plan terms, and policies used
- Identification of specific MH/SUD and medical/surgical benefits subject to the NQTL and which benefits are classified as MH/SUD vs medical/surgical
- Identification of factors, evidentiary standards, sources, strategies or processes considered
- Explanation of whether any factors were weighted more heavily and evaluation of specific data used
- Precise quantitative definitions and supporting sources when applicable
- Explanation of any variation in application between MH/SUD and medical/surgical and the basis for variations
- Descriptions of decisionmakers, timing, and qualifications when decisions determine application
- Description of experts' qualifications if analyses rely on experts
- Proposed findings/conclusions with citations and dates/persons involved in analyses
Support Plan Sponsor fiduciary certification and cooperate with audits
Company shall provide documentation and reasonable assistance to support the Plan Sponsor's fiduciary certification and will cooperate with regulatory reviews or audits upon request. This includes supplying sufficient documentation supporting Section 2 information, reasonably assisting Plan Sponsor's review and confirmation of explanations/findings, working closely to ensure accurate completion of the fiduciary certification, and reasonably cooperating during any regulatory review or audit.
- Provide sufficient documentation to support the comparative analysis information in Section 2
- Reasonably assist Plan Sponsor with review and confirmation of explanations/findings
- Work closely with Plan Sponsor to ensure fiduciary certification is accurately completed
- Reasonably cooperate and assist Plan Sponsor during any regulatory review or audit, upon request
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