"In enforcement actions and audit findings, regulators have consistently identified deficiencies in comparative analyses, particularly where plans cannot adequately document how NQTLs are designed and administered. The most common MHPAEA compliance challenges [include] ... [1] Data access and vendor dependency.... [2] Identifying all applicable NQTLs.... [3] Explaining factors and evidentiary standards ... [4] Demonstrating operational compliance.... [5] Ongoing maintenance obligations.... [6] Fiduciary responsibility.... If this process appears to be complex and overwhelming, that’s because, quite honestly, it is."  MORE >>