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Non-Quantitative Treatment Limitation Comparative Analyses - What are you doing to ensure compliance

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The DOL published FAQs last week. For self funded medical and pharmacy plans, how are you going about preparing the comparative analysis and ensuring compliance? I understand that (at least the PBMs) are not planning on providing this analysis to plan sponsors. Are you looking to law firms, your H&W consultant or elsewhere to make sure the analysis is complete?


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