MHPAEA Requirements
MHPAEA requires that mental health and substance use disorder (MH/SUD) benefits be no more restrictive than medical/surgical benefits in the same classification. This applies to both quantitative treatment limitations (visit limits, copays) and non-quantitative treatment limitations (prior authorization, step therapy, network standards, reimbursement rates).
FAB 2026-03: The Outcomes Shift
The DOL's Field Assistance Bulletin 2026-03 (September 8, 2026) announced a significant shift in MHPAEA enforcement. Plans must now demonstrate parity through outcomes data — not just policy comparisons. Plans that cannot demonstrate comparable outcomes for MH/SUD and medical/surgical benefits will be presumed to be in violation.
Parity as a Strategy
IQ Insight
MHPAEA compliance is not just a legal obligation — it is a health outcome and business performance imperative. Plans that comply with MHPAEA have better mental health access, better treatment rates, and better outcomes. Employees with treated mental health conditions have lower medical costs, lower absenteeism, and higher productivity. Parity compliance is the right thing to do — and it is also the smart business decision.