On Apr. 15, MD INS on non-quantitative treatment limitation reports.
MD INS issued Bulletin 24-10 on mental health and substance use disorder reports.
Provided carriers with updated filing guidance for the non-quantitative treatment limitation (NQTL) analysis reports required by SB 684/HB 1074 provisions, #207520.
Filing Instructions, Data Templates
Deadline to file NQTL reports for 2024 extended to Jul 1 in Bulletin 24-5, #201176.
Carriers should submit the NQTL reports electronically through an encrypted email.
Annotate information within report that should be treated as confidential and provide statutory authority under Public information act that authorizes denial of access.
NQTL reports must be completed using only approved forms and instructions.
New standardized data templates have been developed to evaluate the comparative analysis of certain NQTLs in operation, and existing data templates have been revised.
Comments on templates will be accepted for 30 days following the date of this bulletin.
Final templates will be posted to MD INS after considering all comments received.
Data supplements are required to be filed with the NQTL reports by Jul. 1 deadline.
Report Content
Each carrier, who is subject to MD INS 15-144, must submit an NQTL report for each product offered by the carrier in the individual, small, and large group markets.
For 2024 reports, not necessary to identify the 5 health benefit plans with the highest enrollment for each product and submit a separate report for each of those plans.
2024 NQTL reports should be completed at the product level; provided exceptions.
Must include the results of a comparative analysis conducted by the carrier on prior authorization review process, prescription drug formulary design, and reimbursement.
Also, strategies for addressing provider shortages, and provider network directories.
Report must include attestation by a corporate officer; statement requirements set.
Carriers are reminded that even though reports required to be filed by Jul. 1 include comparative analyses for only 5 NQTLs MD INS 15-144(c)(1) requires additional data.
Included identifying all NQTLs applied to benefits for mental health and substance use disorders, comparative analyses of design and application of all NQTLs on benefits.
Provide each comparative analysis to the commissioner or a member upon request.
Consultation
Comments on proposed data templates must be submitted by May 15, 2024.
NQTL reports and data supplements for 2024 must be filed by Jul. 1, 2024.
