The MPS submitted comments to the Maryland Insurance Administration (MIA) in favor of adding reimbursement rates as a nonquantitative treatment limitation (NQTL) for parity compliance reports. On April 26, 2021 the MIA held a hearing on including reimbursement rates as an additional NQTL for parity reporting required by legislation enacted during the 2020 Maryland General Assembly.  The new law requires insurers and other entities that offer health benefit plans to submit reports to MIA to demonstrate compliance with the federal Mental Health Parity and Addiction Equity Act.  The legislation, codified at Md. Code Ann. Section 15-144, sets forth the content of the reports, which are due in March 2022 and March 2024.

Comments during the November 23, 2020 MIA hearing on compliance reporting revealed the need to add reimbursement rates to the National Association of Insurance Commissioners’ Data Collection Tool for Mental Health Parity Analysis.  MIA will adopt regulations implementing §15-144 by the end of 2021. Comments and materials are being accepted through May 26 via email to MHPAEA.mia@maryland.gov.