mplex regulatory regimes in managed care and will require Health Plans across the industry to adopt new operational and compliance frameworks in the performance of their most basic managed care functions.At its heart, MHPAEA, as outlined in the Final Rule, imposes a burden of presumptive discrimination on all managed care functions and requires Health Plans to prepare and maintain parity compliance documentation that is ready to rebut that presumption at any time upon request. MHPAEA remains the biggest national-level cross-market lever for MH/SUD financing policy, and the Final Rule is a clear indication that at least federal regulators intend to keep using it until MH/SUD treatments are equally accessible as M/S treatments for all patients. ENDNOTES Requirements Related to the Mental Health Parity and Addiction Equity Act [not yet published in the Federal Regulations]. Notice of Proposed Rulemaking CMS-9902-P Requirements Related to the Mental Health Parity and Addiction Equity Act, 88 FR 51552. Some of the less complex requirements go into effect earlier, on January 1, 2025. The Mental Health Parity Act of 1996 (MHPA) Pub. L. No. 104-204, Tit. VII, § § 701-702, 100 Stat. 2874, 2944-50 (Sept. 26, 1996) prohibited the imposition of annual or lifetime dollar limits on MH benefits that were more restrictive than the annual or lifetime dollar benefits applied to medical/surgical benefits in large employer-sponsored plans. However, it did not apply to SUDs, other employer types, or insurance issuers, and it did not restrict the use of discriminatory quantitative benefit limits or cost sharing, or to non-quantitative limits like categorical benefit exclusions for MH/SUD services. The Departments have jointly issued 15 sets of FAQs with 96 questions, eight enforcement fact sheets, six compliance assistance tools and templates, seven reports to Congress, six press releases, and seven consumer publications.See MHPAEA Comparative Analysis Report to Congress, July 2023. Code section 98