"The DOL engaged in less correspondence with health plans and issuers about the NQTLs at issue, but also issued more initial determination letters in the same time period. This indicates that the DOL proceeded with citing MHPAEA violations while asking fewer questions.... CMS issued far more insufficiency letters ... CMS noted there were many times where there was no comparative analysis, and that additional information was still needed even after reviewing the comparative analyses. Both the DOL and CMS issued more final determination letters in 2025 than in prior years showing that they are increasingly willing to cite a plan or issuer ... for providing deficient comparative analyses."  MORE >>