Physician-authored comparative analysis of a health plan's behavioral health UM criteria against its medical/surgical criteria across all six NQTL categories — identifying where the plan is exposed under the Mental Health Parity and Addiction Equity Act.
Side-by-side table covering all six mandated NQTL categories: prior authorization, concurrent review, retrospective review, medical necessity criteria stringency, step therapy/fail-first requirements, and provider network admission standards.
For each NQTL category, a direct comparison of the plan's BH criteria against its analogous M/S criteria — identifying where BH is held to a more restrictive standard.
Written physician analysis explaining the clinical rationale behind identified disparities — why a specific BH restriction has no M/S analogue, why the difference is impermissible rather than clinically justified.
Each identified disparity cited to the specific CFR provision at issue — primarily 29 CFR §2590.712, with applicable DOL/HHS enforcement guidance noted. Framed for attorney use, not as a legal opinion.
Each of the six categories graded: Compliant / Borderline / Exposed — giving the attorney a rapid triage of where the plan faces the most material regulatory risk.
Standard engagement disclaimer framing the deliverable as clinical criteria analysis prepared for attorney review. Legal conclusions remain with retained counsel.
You represent a self-insured employer plan sponsor facing a DOL NQTL inquiry or an MHPAEA enforcement action and need a physician to document the criteria disparity.
You are advising a regional insurance carrier on pre-enforcement NQTL self-assessment ahead of a DOL or HHS audit cycle.
A plan sponsor client is facing a member lawsuit alleging parity violations and you need physician-authored documentation of what the criteria actually say and how they compare.
You are responding to a DOL RFI or civil investigative demand and need a structured, physician-authored criteria comparison to submit as supporting documentation.
Required inputs from client: Summary Plan Description (SPD), clinical criteria manuals (InterQual/MCG/proprietary), Evidence of Coverage (EOC), any prior NQTL self-assessment the plan has conducted.
This is not: a legal opinion, a compliance certification, a guarantee of regulatory adherence, or an attestation that the plan is or is not in compliance. Legal and regulatory conclusions are the responsibility of retained counsel.
Full-format specimen with fictional plan data. Side-by-side NQTL table, risk grading, physician narrative — all six categories demonstrated.
The Clinical Denial Pattern Audit reviews a sample of the plan's actual denial decisions — whether criteria were applied defensibly in practice, not just on paper.
Send only the plan type and general scope first — no documents required to initiate a conversation.