ABHW Shares Recommended Updates to the Self Compliance Tool

Washington, D.C. – April 10, 2026 – The Association for Behavioral Health and Wellness (ABHW), which represents health plans providing behavioral health coverage for approximately 200 million people, has submitted recommendations to the U.S. Departments of Labor (DOL), Health and Human Services (HHS), and the Treasury (collectively “the Departments”) regarding updates to the DOL Self-Compliance Tool (the “Tool”)for the Mental Health Parity and Addiction Equity Act (MHPAEA ) to improve and streamline the mental health (MH) and substance use disorder (SUD) parity compliance process. ABHW fully supports MH and SUD parity, and our members share the same goal as the Departments: promoting access to comprehensive MH/SUD benefits.  

The Self-Compliance Tool was originally developed to assist group health plans, plan sponsors, plan administrators, group and individual market health insurance issuers, state regulators, and other stakeholders in understanding and demonstrating compliance with MHPAEA, and it continues to serve as a valuable foundational resource. However, its practical value has diminished as state and federal regulators increasingly require Non-Quantitative Treatment Limitations (NQTL) comparative analyses that go far beyond the illustrative examples provided. In practice, the Tool no longer reflects the level of specificity, depth, and evidentiary rigor typically expected in state-and federal level MHPAEA reporting.  

As the Departments update the Self-Compliance Tool, ABHW would like to encourage the consideration of the following enhancements:   

• Clearer definitions  
• Standardized templates  
• Additional examples and, where appropriate, thresholds  
• Stronger guidance on data sufficiency, vendor oversight, and documentation 
• Practical examples of compliant and noncompliant analyses 

“Due to significant changes to the reporting requirements over the years, health plans, insurers, employers, and regulators alike have had to spend extra time and resources trying to understand exactly what is needed,” said Debbie Witchey, ABHW President and CEO. “ABHW offers these recommendations to promote greater clarity, consistency and workability in the mental health and substance use disorder parity compliance process.” 

Since its inception, ABHW has been at the forefront of and an advocate for MH and SUD parity and was instrumental in drafting the legislation for the initial MHPAEA of 2008. Our members have worked tirelessly over the past 17 years to implement parity for behavioral health services. ABHW reaffirms its commitment to working with the Administration and the broader behavioral health and employer community to advance policies that improve the parity compliance process and enable health plans to focus resources on expanding access to timely, high-quality mental health and substance use disorder care for patients.

You can read the full letter here.