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Alden Bianchi
Subscribe to Alden Bianchi's PostsAlden J. Bianchi is an experienced Employee Benefits and Executive Compensation lawyer who advises corporate, not-for-profit, governmental and individual clients on a broad range of executive compensation and employee benefits matters, including qualified and non-qualified retirement plans, health and welfare plans. Read Alden Bianchi's full bio.
Parsing MHPAEA Claims Under the Proposed Rule: E.W. v. Health Net Life Insurance Company
By Alden Bianchi on Dec 28, 2023
Posted In Employee Benefits, Mental Health Parity and Addiction Equity Act
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Funding Employer-Sponsored Group Health Coverage: The Group Captive Solution
By Alden Bianchi, Lisa Kaderabek and Teal Trujillo on Dec 13, 2023
Posted In Employee Benefits, Health and Welfare Plans
The enactment of the Affordable Care Act in 2010 led to a sharp increase in employers self-funding their group health insurance plans, with the market tripling in size in the decade that followed. While larger employers can self-fund their group medical coverage in a relatively efficient manner, it does not work well for smaller employers....
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The Proposed MHPAEA Regulations: Comments on Behavioral Health Carve-Out Vendors
By Alden Bianchi on Dec 5, 2023
Posted In Employee Benefits, Health and Welfare Plans, Mental Health Parity and Addiction Equity Act
This post continues our focus on comment letters submitted in response to proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA). The proposed regulations were issued earlier this year by the US Departments of Labor, Health and Human Services and the Treasury (the Departments). Our previous MHPAEA content is available here. The MHPAEA generally...
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The Proposed MHPAEA Regulations: A Comment on the Comments
By Alden Bianchi on Nov 14, 2023
Posted In Employee Benefits, Health and Welfare Plans, Mental Health Parity and Addiction Equity Act
In our last post, we considered some of the comment letters submitted in response to proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA) issued by the US Departments of Labor, Health and Human Services and the Treasury (the Departments). Our previous MHPAEA content is available here. The comment period for the proposed regulations...
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Discerning Congressional Purpose from the Proposed MHPAEA Regulations Comment Letters
By Alden Bianchi on Nov 8, 2023
Posted In Employee Benefits, Health and Welfare Plans, Mental Health Parity and Addiction Equity Act
We continue our investigation of proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA) issued by the US Departments of Labor, Health and Human Services and the Treasury (the Departments). Our previous MHPAEA content is available here. The comment period for the proposed regulations closed on October 17, 2023, and one thing is clear: Stakeholders...
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New MHPAEA Guidance Regarding NQTLs: Network Access and Composition
By Alden Bianchi and Sarah Raaii on Oct 5, 2023
Posted In Employee Benefits, Health and Welfare Plans, Mental Health Parity and Addiction Equity Act
Federal regulators recently announced new mental health parity proposed rules that may add significant new compliance burdens for health plan sponsors, insurers and service providers. The proposed rules may also impact the operation of health plans. A Technical Release accompanied the rules that further explains and invites comment on certain provisions of the proposed rules...
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The Proposed MHPAEA Regulations’ ‘Meaning of Terms’ Part Two: Processes, Strategies, Evidentiary Standards and Other Factors
By Alden Bianchi on Oct 2, 2023
Posted In Employee Benefits, Health and Welfare Plans, Mental Health Parity and Addiction Equity Act
This post continues our investigation of proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA) issued by the US Departments of Labor, Health and Human Services and the Treasury (the Departments). Our previous MHPAEA content is available here. In Part One, we examined the proposed regulations’ definitions of “medical or surgical benefits,” “mental...
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The Proposed MHPAEA Regulations’ ‘Meaning of Terms’ Part One: Benefits
By Alden Bianchi on Sep 26, 2023
Posted In Employee Benefits, Health and Welfare Plans, Mental Health Parity and Addiction Equity Act
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Code § 4980D and Violations of the NQTL Analysis Requirement Under the Proposed MHPAEA Regulations
By Alden Bianchi on Sep 21, 2023
Posted In Employee Benefits, Health and Welfare Plans, Mental Health Parity and Addiction Equity Act
This post continues our investigation of proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA) issued by the US Departments of Labor, Health and Human Services and the Treasury (the Departments). Our previous MHPAEA content is available here. The proposed regulations establish a formal structure for how the Departments will enforce the requirement that...
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The ‘Meaningful Benefit’ Requirement for NQTLs Under the Proposed MHPAEA Regulations
By Alden Bianchi on Sep 13, 2023
Posted In Employee Benefits, Health and Welfare Plans, Mental Health Parity and Addiction Equity Act
In previous posts, we reported on proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA) issued by the Departments of Labor, Health and Human Services, and the Treasury (collectively, the Departments). More recently, we turned our attention to the treatment of non-quantitative treatment limitations (NQTLs), i.e., non-numeric benefit coverage limits that must be no more restrictive...
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