CT Insurance Bulletin MC-24A
Public Act 19-159, An Act Concerning Mental Health and Substance Use Benefits, codified in C.G.S. sec. 38a-477ee. (This bulletin repeals and replacing Bulletin No. MC-24 dated August 31, 2020)
STATE OF CONNECTICUT
INSURANCE DEPARTMENT
www.ct.gov/cid
P.O. Box 816 Hartford, CT 06142-0816
Affirmative Action/Equal Employment Opportunity Employer
BULLETIN MC-24 A
November 30, 2021
TO:
ALL INSURANCE COMPANIES, FRATERNAL BENEFIT SOCIETIES, HOSPITAL
SERVICE CORPORATIONS, MEDICAL SERVICE CORPORATIONS AND
HEALTH CARE CENTERS THAT DELIVER OR ISSUE INDIVIDUAL AND
GROUP HEALTH INSURANCE POLICIES IN CONNECTICUT
RE:
Public Act 19-159, An Act Concerning Mental Health and Substance Use
Benefits, codified in C.G.S. sec. 38a-477ee.
MH/SUD PARITY SUBMISSION GUIDELINES
[NOTE – This Bulletin is being issued (repealing and replacing Bulletin No. MC-24) to update the
reporting documents required for the demonstration of compliance with non-quantitative treatment
limitations (NQTLs) as required to be provided to the Department not later than March 1, 2021, and
annually thereafter.]
This Bulletin is intended to prescribe the requirements for the annual reporting to the Insurance
Department (“Department”) for Mental Health and Substance Use Benefits as required by
Connecticut General Statutes sec. 38a-477ee. Beginning on March 1, 2021 and annually on or
before March 1 of each subsequent year thereafter, each insurance company, fraternal benefit
society, association, and health care center that delivers or issues individual and group health
insurance policies in Connecticut must review its practices and procedures for compliance
with state and federal mental health parity requirements and report its compliance status by
completing the annual Mental Health and Substance Use Benefits compliance report by
following the 5-step analysis instructions attached.
Carriers must demonstrate compliance with non-quantitative treatment limitations (NQTLs) by
providing a detailed explanation of how the analysis of the specific processes, strategies,
evidentiary standards and all other factors used in the application of NQTLs to MH/SUD (mental
health/substance use disorders) benefits demonstrate that the application of such NQTLs is
comparable to and not more stringent than the NQTLs applied to MED/SUR (medical/surgical)
benefits as written as well as in operation. The required report must be submitted and accompanied
by the Certification Cover Letter and Exhibit A to be considered complete.
Beginning March 1, 2021 and annually thereafter the following Mental Health and Substance Use
Benefits compliance report (Exhibit A, Certification Cover Letter) must be submitted to the
Department to demonstrate compliance with state and federal mental health parity requirements.
In addition, each insurance company, fraternal benefit society, association, and health care
center that delivers or issues individual and group health insurance policies in Connecticut
must submit a certification cover letter to the Department signed by an officer of the company.
Insurance Commissioner's singature
The report will be considered incomplete if the certification is not included.
In accordance with C.G.S. sec. 38a-2, any insurance company, fraternal benefit society,
association and health care center that delivers or issues individual and group health insurance
policies in Connecticut that fails to file the completed survey on or before the due date shall
pay a late filing fee of one hundred dollars per day for each day from the date such report was
due, up to a maximum of $15,000. Bulletin MC-24 is hereby repealed.
Questions should be directed to the Market Conduct Division at cid.mc@ct.gov
_____________________________________
Andrew N. Mais
Insurance Commissioner