These findings indicate that most large employer-based health plans have made substantial changes to their benefit designs in response to MHPAEA and the IFR -- by eliminating stricter limits on inpatient days and outpatient visits and higher cost-sharing for MH/SUD inpatient care, as well as higher cost-sharing for outpatient visits in most plans. Although opponents of the law had claimed the new requirements in MHPAEA and the IFR were overly onerous and would cause plans to drop MH/SUD coverage or lower medical/surgical benefits, this has not occurred. This study could not fully capture the extent to which the use of NQTLs changed in response to the law. However, examples are provided in the report of how plans used utilization management techniques and set provider reimbursement rates differently for MH/SUD care compared to medical/surgical benefits and indicate a need for more clarity on how parity requirements apply to these complex areas of benefit management.
More detail on these findings and the methods used to compile and analyze the data are in the final report entitled "Consistency of Large Employer and Group Health Plan Benefits with Requirements of the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008." The report was authored by NORC at the University of Chicago and a research team that included Milliman, Inc., Aon Hewitt, Truven Health Analytics, and George Washington University. The report is available at http://aspe.hhs.gov/report/consistency-large-employer-and-group-health-plan-benefits-requirements-paul-wellstone-and-pete-domenici-mental-health-parity-and-addiction-equity-act-2008.