Overview
The Obama Administration’s focus on the problems of mental health and substance use disorders continues to intensify. In late 2015, President Obama addressed a presidential memorandum to a number of executive agencies, including the heads of the Departments of Labor (DOL), Treasury, and Health and Human Services (HHS) regarding wide-spread addiction to heroin and prescription drugs and urging the agencies to accelerate their efforts to combat addiction.1 Both the DOL and HHS are focusing new regulatory and enforcement initiatives on the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA), which became effective January 1, 2014.2 On June 2, 2016, the DOL released a checklist for MHPAEA compliance.3
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1 Memorandum on Addressing Prescription Drug Abuse and Heroin Use, 2015 Daily Comp. Pres. Doc. 743 (Oct. 21, 2015); Office of the Press Secretary, Fact Sheet: Obama Administration Announces Additional Actions to Address the Prescription Opioid Abuse and Heroin Epidemic (Mar. 29, 2016. Both the Presidential Memorandum and the Fact Sheet are available at www.whitehouse.gov/briefing-room.
2 The Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008; H.R. 1424, 110th Cong. (2008) (MHPAEA). MHPAEA amended the following federal statutes: 29 U.S.C. § 1185a, § 712 (ERISA); 42 U.S.C. § 300gg–5, § 2705 (Public Health Service Act); and I.R.C. § 9812 (Internal Revenue Code or Code).
3 DOL, Warning Signs – Plan or Policy Non-Quantitative Treatment Limitations (NQTLs) that Require Additional Analysis to Determine Mental Health Parity Compliance, available at https://www.dol.gov/ebsa/ (hereinafter NQTL Warning Signs).
