"According to the Court, a plaintiff must: [1] Provide a valid determination that the health plan is subject to MHPAEA; [2] State what the underlying Quantitative/Nonquantitative Treatment Limitation (QTL/NQTL) being used by the plan to deny or limit benefits; [3] Name the [medical and surgical (M/S)] benefit used to compare to the MH/SUD benefit in question; and [4] Explain how the health plan applies the QTL/NQTL differently to the M/S benefit than to the MH/SUD benefit. Significantly, the Court did not apply any sort of reasoning requiring that outcomes of MHSUD claims be consistent with M/S claims." [E.W. v. Health Net Life Ins. Co., No. 21-4110 (10th Cir. Nov. 21, 2023)]  MORE >>