Alden Bianchi

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Alden 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 MHPAEA Proposed Rule: ‘Meaningful Benefits’ and the ‘Scope of Services’


By on Feb 20, 2024
Posted In Employee Benefits, Health and Welfare Plans, Mental Health Parity and Addiction Equity Act

This post continues our consideration of comments submitted in response to proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA). Our previous MHPAEA content is available here. Under current law, if a plan provides any mental health or substance use disorder (MH/SUD) benefits in any classification of benefits, benefits for that condition or use disorder...

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The MHPAEA Proposed Rule: Standards of Care and Medical Necessity


By on Feb 1, 2024
Posted In Employee Benefits, Health and Welfare Plans, Mental Health Parity and Addiction Equity Act

Comments submitted in response to the proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA) reflect a broad range of perspectives. Our previous MHPAEA content is available here. A nontrivial subset of the comments single out a particular nonqualified treatment limitation (NQTL) for special treatment or scrutiny. An example of this trend is...

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The MHPAEA Proposed Rule: Scalability and the Plight of the Small(er) Self-Funded Plan


By on Jan 4, 2024
Posted In Employee Benefits, Health and Welfare Plans, Mental Health Parity and Addiction Equity Act

After a brief hiatus to discuss the pleading standards adopted by the US Court of Appeals for the Tenth Circuit in E.W. v. Health Net Life Insurance Company, we return to our examination of the comments submitted in response to the proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA). The US...

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Parsing MHPAEA Claims Under the Proposed Rule: E.W. v. Health Net Life Insurance Company


By 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 , and 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 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 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 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 and 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 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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