On September 8, 2026, the Department of Labor issued new enforcement guidance regarding the Mental Health Parity and Addiction Equity Act (MHPAEA) and its nonquantitative treatment limitation (NQTL) requirements.
Under MHPAEA, group health plans must ensure that any nonquantitative treatment limitations (NQTLs) affecting mental health and substance use disorder (MH/SUD) benefits are designed and applied in a manner comparable to, and no more restrictive than, those applied to medical/surgical benefits.