Title: Mental Health Parity and NQTL Analysis
Source: https://ethosbenefits.com/services/mental-health-parity
Publisher: Ethos Benefits
Summary: Ethos Benefits coordinates your plan’s NQTL comparative analysis under the Mental Health Parity and Addiction Equity Act and keeps it current.

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# 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.

[Request a Strategic Analysis](https://ethosbenefits.com/strategic-analysis)

## 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.

1.  **NQTL inventory** Every nonquantitative treatment limitation in the plan identified, such as prior authorization, step therapy and network admission standards.
2.  **Comparative analysis** The written analysis comparing how each limit applies to mental health and substance use disorder benefits versus medical and surgical benefits, coordinated with your vendors.
3.  **Vendor coordination** The data and documentation each vendor must supply, requested and tracked.
4.  **Annual update** The analysis reviewed and updated each year and whenever the plan or the rules change.
5.  **Regulator readiness** The 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™](https://ethosbenefits.com/fiduciary-framework) · [How fiduciary governance works](https://ethosbenefits.com/services/fiduciary-governance)

## Related reading.

-   [**NQTLs and mental health parity** Benefits 101: What an NQTL is, how it differs from a quantitative limit, which employer plans need a written NQTL comparative analysis, and where the 2024 parity rule stands.](https://ethosbenefits.com/benefits-101/mental-health-parity-nqtl)
-   [**The ERISA compliance checklist** Benefits 101: An ERISA compliance checklist for employer health and welfare plans, with each document, notice and filing, who it applies to, and when it is due.](https://ethosbenefits.com/benefits-101/erisa-compliance-checklist)
-   [**ERISA health plan litigation** Insight: ERISA health plan lawsuits over drug prices, PBM contracts, tobacco surcharges and voluntary benefits. What each case alleges, where it stands, and what to do.](https://ethosbenefits.com/insights/erisa-health-plan-litigation)

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## Sources

1.  [Mental health and substance use disorder parity](https://www.dol.gov/agencies/ebsa/laws-and-regulations/laws/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.

## Keep reading Related to this page.

-   [**Compliance** Ethos Benefits keeps your health and welfare plans compliant with ERISA, the ACA, COBRA, HIPAA, mental health parity and the CAA, with every item proven. _Read more_](https://ethosbenefits.com/services/compliance)
-   [**ERISA compliance** Ethos Benefits keeps your health and welfare plans ERISA compliant: plan documents, SPDs, required disclosures, Form 5500, bonding and provider disclosures. _Read more_](https://ethosbenefits.com/services/erisa-compliance)
-   [**Pharmacy and PBM** Ethos Benefits reviews your PBM contract and pharmacy spend, finds where spread pricing and rebates go, and helps your committee decide what to change. _Read more_](https://ethosbenefits.com/services/pharmacy-pbm)
-   [**ACA compliance and reporting** Ethos Benefits keeps your company ACA compliant: employer mandate, affordability, SBCs and PCORI fees, plus Forms 1094-C and 1095-C as an added service. _Read more_](https://ethosbenefits.com/services/aca-compliance)
-   [**Nondiscrimination testing** Ethos Benefits runs Section 125, dependent care and Section 105(h) nondiscrimination testing so your plans keep their tax advantages for every employee. _Read more_](https://ethosbenefits.com/services/nondiscrimination-testing)

## 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.

[Request a Strategic Analysis](https://ethosbenefits.com/strategic-analysis) [Call (407) 803-4710](tel:+14078034710)
