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Deductibles

Can plan sponsors apply a separate medical and mental health deductible (as long as the mental health deductible is not higher)?

Absent any regulations, Aetna's best understanding of the MHP Act is that separate but equal medical and mental health deductibles can be applied (or lesser for mental health benefits). Aetna does not currently offer a plan with separate deductibles, although one may be introduced in the future should the regulations allow. In Aetna’s response to the request for information from the regulators, Aetna has in fact requested confirmation that both the intent of the law and the language of the law allow for either combined or separate deductibles and out-of-pocket maximums.

If our medical plan has a deductible, but our mental health carve-out plan does not, can we keep the more generous benefit for the mental health carve-out plan?

Absent any regulations, Aetna's best understanding of the MHP Act is that if the benefit for the mental health carve-out plan is more generous, it may be retained.