1. Drop mental health coverage -- not a logical choice
2. Seek exemption -- must comply for at least 6 months
3. Comply with the mandate of the Act -- our recommendation
What is the mandate of HR 3666?
To adopt the same annual and lifetime dollar limits for mental health benefits that
apply to medical benefits
Recommended Plan Design
The following numbers will apply for Mental/Nervous Treatment* per plan year:
Inpatient Acute
14 Days
Inpatient Sub-acute
14 Days
Day Treatment/PHP
28 Days
Residential
40 Days
IOP
6 Weeks
Outpatient
50 Sessions
Additionally:
A plan co-payment of at least 80 percent for all levels of mental health treatment
should be provided for in-network.
If there are non-network benefits, the co-payment difference between network and
non-network should be at least 30 percent. Also, if non-network benefits are provided, the
plan document should state that those charges will be re-priced per a non-network fee
schedule and include a significant precertification penalty. For private employers under
ERISA, a plan design with no benefits (except in an emergency) for out-of-network
treatment should be considered by the employer.
