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American Benefits Council Comments to EBSA on Proposed FAQs About MH/SUD Parity Implementation and the 21st Century Cures Act
American Benefits Council 
[Opinion] June 25, 2018
"The Departments should clarify that a plan only violates MHPAEA where it cannot demonstrate that the processes, strategies, evidentiary standards, or other factors considered by the plan in implementing the NQTL are comparable to and applied no more stringently to MH/SUD benefits as compared to M/S benefits."
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