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.
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...
Continue Reading
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...
Continue Reading
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...
Continue Reading
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...
Continue Reading
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...
Continue Reading
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
Continue Reading
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...
Continue Reading
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...
Continue Reading
Takeaways from a Recent COBRA Notice Class Action Settlement
By J. Christian Nemeth, Alden Bianchi and Joseph Wasserkrug on Sep 12, 2023
Posted In Employee Benefits, Health and Welfare Plans
There has been a flurry of class action lawsuits and settlements relating to the deficiency of required election notices under the Consolidated Omnibus Budget Reconciliation Act (COBRA). The notices provide employees and their beneficiaries who participate in an employer’s group health plan with the option to elect to continue their coverage following a COBRA qualifying...
Continue Reading
The ‘Data Evaluation Requirement’ for NQTLs Under the Newly Proposed MHPAEA Regulations
By Alden Bianchi on Sep 7, 2023
Posted In Employee Benefits, Health and Welfare Plans, Mental Health Parity and Addiction Equity Act
Last week’s post examined the “no more restrictive” requirement that would apply to non-quantitative treatment limitations (NQTLs) set out in recently proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA). (Our description of the proposed regulations is available here.) The proposed regulations deal principally with NQTLs, which are non-numeric benefit coverage limits...
Continue Reading
