Mental health parity. The NQTL comparative analysis.

If your group health plan covers mental health or substance use disorder benefits, federal parity law requires a written comparative analysis showing that limits like prior authorization and network rules are no stricter for those benefits. As an added service, Ethos Benefits coordinates that NQTL analysis with your vendors and keeps it current.

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What you get.

Most of the data for the analysis sits with your carrier, administrator and PBM, but the plan is responsible for having it. Regulators can ask for it at any time.

NQTL inventoryEvery nonquantitative treatment limitation in the plan identified, such as prior authorization, step therapy and network admission standards.
Comparative analysisThe written analysis comparing how each limit applies to mental health and substance use disorder benefits versus medical and surgical benefits, coordinated with your vendors.
Vendor coordinationThe data and documentation each vendor must supply, requested and tracked.
Annual updateThe analysis reviewed and updated each year and whenever the plan or the rules change.
Regulator readinessThe analysis kept on file and ready to produce if the Department of Labor or a participant asks for it.

What the analysis must show.

For each limit, the analysis describes the limit, the benefits it applies to, the factors and evidence used to design it, and how it is applied in practice to mental health and substance use disorder benefits compared with medical and surgical benefits. The Consolidated Appropriations Act, 2021 requires plans to have this analysis written down and available on request.

Who does what.

Your carrier, administrator and PBM hold most of the information. The plan is responsible for the result. Ethos requests what each vendor must provide, reviews it for gaps, and keeps the finished analysis in your record.

Part of your Fiduciary Framework™.

Every Ethos service reports to your benefits committee. The work is reviewed at your quarterly committee meeting, each decision is recorded with the reasoning behind it, and the record lives in your Ethos Fiduciary OS. That is what lets your committee show the plan was run prudently.

See the Fiduciary Framework™ · How fiduciary governance works

Sources

Mental health and substance use disorder parity, U.S. Department of Labor, Employee Benefits Security Administration

Questions employers ask about this.

What is an NQTL?

A nonquantitative treatment limitation is a limit on benefits that isn’t a number, such as prior authorization, step therapy, network standards or medical necessity criteria. Parity law requires these to be applied no more strictly to mental health and substance use disorder benefits.

Does this apply to fully insured plans?

Yes. Parity rules apply to group health plans that cover mental health or substance use disorder benefits, whether insured or self-funded, though the carrier usually supplies most of the analysis for an insured plan.

Haven’t the parity rules changed?

Yes, more than once since 2021, and enforcement of the newest rules has been in flux. Ethos tracks the changes and updates the analysis when they take effect.

See what your plan is really costing you.

A Strategic Analysis starts with your plan documents and your broker agreement, then shows you what your plan costs, where the risk sits, and what a committee would decide with the full picture.

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