Six factors
Factors considered in designing the NQTL, including the specific processes, strategies, evidentiary standards, and other factors used — all present, or the analysis does not release.
The most defensible NQTL comparative analysis a self-funded plan can have.
ParityProof assembles a documentation-complete NQTL comparative analysis — every statutory factor, every content element, the fiduciary certification packet, and the annual refresh calendar — checked against the letter of MHPAEA and the 2024 Final Rule before a specialist releases it.
Every factor of MHPAEA §2726(a)Nine content elements, gate-checkedPlan document · medical policy · network data ingestionSpecialist release on every analysisAnnual refresh SLA
Why analyses fail
A single missing element can trigger a DOL determination letter.
A self-funded plan's NQTL comparative analysis is only as strong as the documentation behind it. Miss one of the nine required content elements, skip the 'in operation' data, fail to address a single NQTL, or rely on conclusory statements — and the DOL will cite the analysis as insufficient, triggering a determination letter, potential corrective action, and fiduciary liability.
Most plans produce this analysis by hand, from memory, once per plan year. The 2024 Final Rule has not been read end-to-end since it was published. That is exactly where completeness gaps hide.
ParityProof exists to close that gap with a single, exhaustive standard applied identically to every file.
Nearly all
of analyses reviewed by regulators were insufficient on initial receipt
The benchmark
Measured against the letter of the statute and the Final Rule — subsection by subsection.
We do not summarize the law and hope. Every analysis is scored against a versioned rule pack tied to the exact text of MHPAEA §2726(a) and the 2024 Final Rule. These are the provisions each analysis is held to.
Nine content elements
Description of the NQTL, identification of the MH/SUD and medical/surgical benefits, comparative analyses, and the specific findings and conclusions — each element gate-checked.
As written and in operation
The analysis must cover both the plan's written terms and the actual application of the NQTL, using relevant data on claims, denials, and network adequacy.
Annual refresh
The analysis is updated each plan year, with changes in NQTLs, data, or legal requirements documented and re-verified.
Fiduciary certification
A named ERISA plan fiduciary must certify that a qualified service provider prepared the analysis, with the certification included in the deliverable.
Rapid response readiness
The analysis is structured and indexed so that within 10 business days of a DOL request, the plan can produce the complete analysis and supporting documentation.
How an analysis is built
Intake to specialist release, with deterministic gates the AI cannot overrule.
AI extracts and drafts. Deterministic rules — running as code, outside the model — decide what is complete. A human specialist signs every release. That order is never reversed.
01
Completeness Gap Scan
Upload the plan document, medical-management policies, and network/reimbursement data. We return a free completeness read: which NQTLs and content elements you already have, and which are missing.
02
Document ingestion & NQTL identification
As your authorized clerical agent, we ingest the SPD, plan document, UR criteria, provider network contracts, and claims data. AI identifies every NQTL and maps it to the six factors.
03
Grounded drafting
The nine content elements are drafted from your validated data and the MHPAEA rule pack into field-locked templates — no legal opinions, no invented facts.
04
Deterministic completeness gates
All NQTLs are identified; each factor is addressed; the 'in operation' data is reconciled; the fiduciary certification is drafted; any failure blocks release.
05
Specialist release
An ERISA/benefits expert reviews the exception queue and signs the release. High-complexity or multi-state plans route to attorney review first.
06
Delivery
You receive the analysis: the full comparative analysis document, the evidence log, the fiduciary certification packet, and the annual refresh calendar — ready for the plan sponsor to certify and file.
The bar we hold
Rigor you can measure.
100%
Specialist-released
No analysis ships without a human signature.
10 days
Standard SLA
From complete intake to released analysis.
<1%
Critical-defect target
Tracked against a gold-standard analysis library.
6
Factors addressed
Every NQTL mapped to the six statutory factors, every time.
Why ParityProof
Built to be the most thorough option a plan sponsor has.
Documentation-complete, by design
The deliverable is completeness itself — every NQTL, factor, and content element accounted for or explicitly exception-coded. Nothing is left implicit.
Deterministic, not vibes
The gates that decide completeness are code, not a model's opinion. A drafting error cannot slip past a statutory requirement.
In its lane, on purpose
We prepare documentation and run searches as your clerical agent. We never provide legal advice, and the named fiduciary retains all certification authority.
Engagement
Flat fee, per released analysis. No hourly billing, ever.
Simple, predictable, and aligned with a documentation standard — not a cut of any recovery.
- A free Completeness Gap Scan before you commit — see exactly what is missing.
- One flat fee per released NQTL Comparative Analysis; disclosed pass-through data acquisition costs.
- Optional fixed-fee attorney review for high-complexity or multi-state plans.
- Optional Annual Refresh Retainer for ongoing compliance and rapid-response readiness.
FAQ
Questions, answered precisely.
Is ParityProof a law firm?
No. ParityProof, a service of Your Deputy, Obuke LLC, provides documentation-completeness services. It is not a law firm, does not provide legal advice, and does not represent you in any legal matter. Attorney review is available and recommended for complex or high-risk plans.
Do you contact the DOL or regulators?
Never. ParityProof is not a legal representative and does not communicate with regulators on your behalf. The plan sponsor and its counsel remain responsible for all regulatory interactions.
What makes an analysis 'complete'?
Completeness is defined by the statute: all NQTLs identified, all six factors addressed, all nine content elements present, the 'as written and in operation' data reconciled, and the fiduciary certification drafted. Deterministic gates enforce each one before release.
How fast is it?
The standard SLA is 10 business days from complete intake to a specialist-released analysis. The free Gap Scan is returned much sooner and tells you exactly what is still needed.
How are you priced?
A flat fee per released analysis, plus disclosed pass-through data costs. No hourly billing and no percentage of any plan savings or recoveries.
See what's missing before the DOL asks.
Start with a free Completeness Gap Scan. Send your plan document, medical policies, and network data and we'll return a completeness read against every factor and element of MHPAEA.
Documentation-completeness service · not legal advice · the plan sponsor retains all fiduciary duties.