Regulation

CAA 2021 § 203

Section 203 of the Consolidated Appropriations Act of 2021 added an affirmative duty: group health plans must perform and document a written comparative analysis of their non-quantitative treatment limitations (NQTLs) for MH/SUD benefits versus medical/surgical benefits, and provide that analysis to plan participants or the Departments of Labor, HHS, or Treasury on request. This statutory disclosure obligation applies regardless of the 2025 federal non-enforcement of the 2024 MHPAEA Final Rule — the CAA 2021 text is a separate statute enacted by Congress.

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