EP 142: Recent DOL Enforcement on MHPAEA and Applied Behavior Analysis (ABA) Therapy Exclusions

In this episode, Chase Cannon and Suzanne Spradley discuss recent enforcement on MHPAEA. Chase jumps in with a description of DOL’s enforcement approach, including working through TPAs to identify plans that have or had ABA therapy exclusions. Suzanne and Chase discuss the administrative challenges with reprocessing ABA exclusion claims, which the DOL is asking TPAs to assist plans with. The two close with a high-level review of the recent DOL Enforcement Fact Sheet and promise a more in-depth review of the recent MHPAEA proposed regulations and report to Congress on the next podcast.