MHPAEA Compliance Officer — 2026 Enforcement
The 2026 MHPAEA Final Rule requires health plans to designate a compliance officer accountable for parity enforcement. This role has increased scrutiny after DOL 2025 enforcement actions.
Compliance Officer 2026 Duties
- NQTL (Non-Quantitative Treatment Limits) documentation
- Comparative analysis for medical/surgical vs BH benefits
- Prior auth pattern review
- Network adequacy verification
- Provider reimbursement parity analysis
Provider Playbook
- Request comparative analysis from payer
- Document parity violations with pattern evidence
- File complaint with EBSA or state DOI
- Track parity-related denials as leverage
Ripe Parity Denials
90837 downcoding to 90834, PHP/IOP LOS limits, SUD residential denials, autism ABA quantitative limits, telehealth vs in-person disparities.
$1.04M case study · Free audit
– KD, Revenant Care