"Despite providing significantly more details, many unanswered questions remain.... If left up to the reporting plan sponsor to answer these questions, those using specialized vendors for MH/SUD services will have more challenges to ensure consistency in consolidating the required reports between M/S and MH/SUD vendors and care management firms.... The requirement for a named fiduciary to review the analysis and certify that it complies with the content requirements is a significant development that puts trustees and other fiduciaries at risk for a failure to make sure the comparative analysis complies with the new requirements."

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