"The enforcement actions reflect the first instance in which DOL has initiated litigation to enforce MHPAEA against a health insurance issuer, health plan, or administrative service provider in the 13 years since the initial passage of the statute.... [I]ssuers and health plans should carefully review both the consistency of the factors they use to determine which benefits should be subject to a given [non-quantitative treatment limitations (NQTL)] type as well as the ratio of mental health/substance use disorder benefits subject to an NQTL type compared to the application of the same NQTL to medical-surgical benefits in the same classification." [Walsh v. United Behavioral Health and UnitedHealthcare Ins. Co., No. 21-4519 (E.D.N.Y. settlement agreement filed Aug. 11, 2021); Walsh v. UnitedHealth Group Inc. and Oxford Health Ins. Inc., No. 21-4519 (E.D.N.Y. settlement agreement filed Aug. 11, 2021)]