Mental Health Parity Act (MHPA)- Small Group

This same information was sent out recently. The Blue Shield information is now included.

Mental Health Parity became effective October 3, 2009 requiring group health plans to offer both medical benefit and mental health/substance abuse benefits in parity. 

Aetna will be using the information provided on the Employer Verification Form to determine if a group is subject to Mental Health Parity.  Employers are requested to complete this form approximately 6 months after their effective date or renewal date. 

For current Small Group accounts up for renewal that have 51 or more employees for 50% of the previous calendar year, Aetna will apply the MHP benefit changes and increase the premium by approximately 1% to account for the new benefits.

• Groups with 51+ renewing in small group that have Pick-A-Plan may make plan changes during open enrollment.
• Groups with 51+ renewing in small group that do not have Pick-A-Plan will be required to renew ‘as-is’ with no plan changes.  If plan changes are sought, the group must:
  
  -Transition to Midmarket, or
  
  -Request through Small Group Underwriting to add Pick-A-Plan to their policy.  Small Group underwriting will review the request and either approve or decline the request.  (If declined, the group must renew ‘as-is’ or move to Midmarket.)

For prospects of writing non-GI groups with 51 or more employees under small group, we currently are not accepting these types of groups. (This applies to carve-outs when the total size of the employer is over 50, and to employers over 50 that have been declined in Midmarket.) 

Final legislation to calculate the number of ‘eligible’s’ has not been published yet.  In the meantime, Aetna will calculate the group size based upon the number of employees eligible for the group plan (those working more than 30 hours per week).

Updated – At the time we sent this first notice, Blue Shield was “business as usual until further notice”

Blue Shield has announced their position regarding this new Mental Health Parity Law – details below

To comply with this newly implemented law, affected small groups with coverage issued or renewed on or after October 15, 2009 that offer mental health or substance abuse coverage will receive updated plan benefits at their qualifying renewal date, once Blue Shield is notified.

Which Small Groups are affected?
Groups that qualify as a “large employer” under the Federal definition are required to comply with HR1424. Unlike the CA state definition of group size, which is based on eligible employees, the Federal definition of a large employer is based on the total number of employees. To meet the Federal definition of a large employer, groups must have had more than 50 total employees, including seasonal and/or part-time employees, for at least 6 months of the previous calendar year. Groups enrolled under a small group policy that meet this criteria must comply with HR1424. This mandate does not affect small groups with less than 50 total employees, Individual and Family Plans, or Medicare.

Once Blue Shield is notified that a small group meets the above criteria, Blue Shield will ensure that their medical plan benefits provide inpatient and outpatient mental health benefits at parity to their medical benefits effective as of their qualifying renewal date. Additionally, if the group chooses to offer substance abuse benefits, those benefits will also be provided at parity per the mandate of HR 1424.

What steps should be taken to identify which groups must comply?
Technically, if you have a client who meets the Federal definition of a large employer, they are responsible for ensuring that their group health plan complies with HR 1424. As the broker of record for your small group accounts Blue Shield is asking that you advise them of this important federal law and ask them to confirm whether they meet the definition of a large employer under Federal law. Then please notify Blue Shield of any affirmative responses. Information on how to notify Blue Shield of groups that must comply is set forth below. In addition, the renewal guide in the employers’ renewal packet will also include information regarding the Mental Health Parity requirement.

What do I need to do if I have affected small group clients?
As you determine a small group client is affected, please send the following documentation to Blue Shield Small Group Underwriting department for verification that the group meets the criteria:
? Cover letter indicating that the group meets Federal group size for the Mental Health Parity
? Two quarters of the group’s DE6 for the calendar year prior to the renewal showing more than 50 total employees

This information may be faxed to Small Group Underwriting at (209) 371-3834 or emailed to SGUW@blueshiedca.com or please let us assist you.

 Effective November 1, 2009 new or renewing Small Groups will have to be compliant with these new MHPAEA-compliant benefits. Impacted renewing groups will move to compliant plans upon their renewal beginning November 1, 2009. HN will ask employer groups to complete the acknowledgment form (see attached) to enroll in an MHPAEA-compliant plan(s) By signing this acknowledgment form, groups agree to add this coverage to their plan benefits retroactive to their effective date at the premium stated on the acknowledgment form.

Renewing small business groups with 51 or more employees but less than 50 enrolled may contact HN Acct Management to help transition over to an MHPAEA-compliant plan or please let us assist you.

UHC policy is for groups of 51+ in the 2-50 small group market, UHC is going to auto renew these groups in the small group market on the group’s current plans only.  This MHPA is not available to the 2-50 small group market. If the Employer knows they are out of compliance they need to request a 51+ proposal to move to the 51-99 market. UHC is leaving it up to the Employer to disclose whether or not they are in compliance.

 
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