On April 26, 2010, the New York Insurance Department (the “NYID”) proposed a circular letter to provide additional guidance to insurers on the impact of the federal Mental Health Parity and Addiction Equity Act of 2008 (the “Act”). This proposed circular letter is a supplement to Circular Letter No. 20 (2009), and addresses interim final rules issued subsequent to Circular Letter No. 20 (2009) by the United States Department of the Treasury, Department of Labor and Department of Health and Human Services. In particular, the proposed circular letter discusses:
- Inpatient substance use disorder benefits
- Financial requirements: primary care copayment vs. specialty care copayment
- Utilization reviews under Articles 49 of the Insurance and Public Health laws
- Policy form and rate submissions
The proposed circular letter is addressed to all insurers authorized to write Accident and Health insurance in New York State, Article 43 corporations, and health maintenance organizations. The NYID invites comment from these insurers until May 10, 2010. If you would like EAPD to assist you with preparing and submitting comments, please click the “Email the Editor” button and provide your contact information for follow-up by an EAPD attorney.
To see a copy of the Act, click here.