The MPS joined other groups in the Maryland Parity Coalition in two follow up letters to the Maryland Insurance Administration (MIA) that were drafted by Legal Action Center. The comments relate to parity compliance reporting templates and draft Maryland regulations to ensure uniform definitions and methodology for reporting health plan compliance with state and federal standards under the Mental Health Parity and Addiction Equity Act.
The first letter requests further clarification on a non-quantitative treatment limitation (NQTL) entry – the prescription drug formulary design analysis – and several revisions to the summary form to give more guidance to consumers who are likely to need information about the Parity Act and the plan design features to make full use of the issuer’s report. We urge the MIA to require submission of data in the templates as part of the NQTL report. Outcome data is essential to determine in operation compliance of key NQTLs and is consistent with federal requirements.
The second letter reiterates that mental health disorder benefits and substance use disorder benefits must be reported separately and urged that MH/SUD be removed and replaced with the full terms “mental health benefits” and “substance use disorder benefits.”