"The Final Rule indicates that plans and issuers are ultimately responsible for MHPAEA compliance but that TPAs or other service providers who act as fiduciaries for ERISA-covered group health plans must work with those plan sponsors or issuers to ensure such compliance ... The Departments declined to follow commentators' suggestion that the Final Rule require that plans enter into contracts with TPAs similar to HIPAA business associate agreements that would require TPAs to cooperate with the plans' compliance obligations pursuant to the MHPAEA."  MORE >>