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Joanne Roskey Quoted on Need for DOL Example of Compliant Comparative Analysis in Guidance in Law360

"3 Items On Attys' Wish List For Mental Health Parity Guidance"


Joanne Roskey, former Chief of the Division of Health Investigations for the Department of Labor's (DOL) Employee Benefits Security Administration (EBSA), was quoted on what would be helpful from DOL as it prepares for new mental health parity guidance. Roskey said an example of a compliant comparative analysis would be "a welcome form of guidance." She noted the regulated community is "still struggling with how to prepare a compliant comparative analysis." Some issues where clarity is needed, she said, are "what the agencies are looking for, how granular and complete an analysis it must be, [and] how many levels deep of analysis plans have to go and issuers have to go in terms of delineating in a written document what their processes, strategies and evidentiary standards are." Roskey said that could come in the form of examples or even a "template that could be utilized to guide plans and issuers."