Comparative Analysis

The written document a health plan must produce under CAA 2021 § 203 demonstrating that its NQTLs for MH/SUD benefits are no more restrictive than those for comparable medical/surgical benefits. On request, the plan must provide the analysis to plan participants, treating providers, and the Departments of Labor, HHS, and Treasury. Requesting this document in writing is a powerful step in any MHPAEA-based appeal because noncompliance triggers regulatory action.