Susan M. Adams
Associate Chief Counsel
Legal & Public Affairs

900 Cottage Grove Road B6LPA
Hartford, CT 06152
860.226.8700

May 28, 2009

Attn: MHPAEA Comments

Office of Health Plan Standards and Compliance Assistance
Employee Benefits Security Administration

Room N-5653

U.S. Department of Labor

200 Constitution Avenue, NW

Washington, DC 20210

Attn: CMS-4137-NC

Centers for Medicare & Medicaid Services
Department of Health and Human Services
P.O. Box 8017

Baltimore, MD 21244-8010

CC:PA:LPD:PR (REG-120692-090)
Room 5205

Internal Revenue Service

P.O. Box 7604

Ben Franklin Station
Washington, DC 20044

Submitted via the Federal eRulemaking Portal: www.regulations.gov

Re: Request for Information Regarding the Paul Wellstone and
Pete Domenici Mental Health Parity and Addiction Equity Act of 2008
(74 Fed. Reg. 19155, April 28, 2009)

Dear Sir/Madam:

Connecticut General Life Insurance Company (“CIGNA”) is writing to comment regarding
implementation of the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction
Equity Act of 2008 (Pub. Law 110-343, the “MHPAEA”). We are responding to a Request for
Information (“RFI”) published in the Federal Register on April 28, 2009 (74 Fed. Reg. 19155).

CIGNA is a health insurer and administrator of self-funded group health plans covering

approximately 10.2 million individuals. We provide managed medical, pharmacy and dental
care services, including integrated indemnity and group life and health insurance, primarily to

Proud National Sponsor of the March of Dimes WalkAmerica for Healthier Babies


May 28, 2009
Page 2

employees whose coverage is provided by their employer. CIGNA also offers behavioral health
benefits, assistance and work/life support programs, medical management and a range of
industry-leading health & wellness and behavior-change coaching services.

While we have read and support many of the issues raised by America’s Health Insurance
Plans, of which we are a member, we wish to draw your attention to the following issues
specifically:

¢ Clarification is needed as to which group health plans and group health insurers are
subject to the MHPAEA, including how to determine if an employer has SO or fewer
employees and whether employee assistance programs (“EAPs”) are governed by the
MHPAEA.

e Clarification is needed regarding appropriate methods to determine parity with respect
to financial requirements and treatment limits, including confirmation that a plan
may impose separate (but no more restrictive) financial requirements and treatment
limits to mental health or substance use disorder benefits and that plans may
determine parity based on a comparison of place of service, e.g. in-patient medical
services to in-patient mental health services.

e The disclosure of medical necessity criteria to consumers and health care providers
should be done in compliance with existing ERISA requirements.

¢ The group health plans' or group health insurers' ability to define mental health or
substance use disorder benefits should be affirmed.

We look forward to working with you to implement this important legislation. Please feel free
to contact me at 860.226.8700, if you have any questions.

incerely, ,
‘ ) / /

hy U/ UV Mint

uf M .
| asa’ M: Adams