MHPAEA · NQTL Comparative Analysis
Fidvciary generates the mental health parity compliance analysis your self-funded plan is legally required to have, structured to the Department of Labor's own audit framework. The report will be ready for your counsel to review in days, not built from scratch over months.
A software platform built on the DOL Self-Compliance Tool methodology. Fidvciary is not a law firm and does not provide legal advice.
Exposure
For years, plan sponsors could point to good-faith effort. That era is over. The regulator and the plaintiffs' bar have converged on the same requirement at the same time — a documented, plan-specific analysis of how your health plan treats mental health and substance-use benefits. Most plans do not have one.
The 2024 MHPAEA Final Rule eliminated the education-only path. Plan fiduciaries are now expected to perform and document a comparative analysis of every non-quantitative treatment limitation, and to produce it upon request. Enforcement and private litigation have moved in the same direction at once.
The committee structures, documented reviews, and record retention are now in healthcare. Health plan spend is the second-largest line item after payroll and courts have begun to treat fiduciary duty over it as a necessity.
When an audit letter or a complaint arrives, the strongest position is a documented, plan-specific, methodology-traceable analysis ready to produce. Its absence is grounds for a lawsuit.
In their reports to Congress, the Department of Labor has stated that none of the comparative analyses initially reviewed were sufficient as submitted — an aggregate signal of how far most plans sit from the current standard.
Current solutions
The requirement sits in the gap between legal expertise and software. The people with ERISA depth don't have a platform; the people with a platform don't have ERISA depth. That gap is the reason the work stalls.
Law firms & specialist analysts
$10k–$40k per engagement · 8–16 weeks
Generic HR / GRC platforms
Proven non-compliant/incomplete
Claims administrators
Data sits where you can't use it
The synthesis
Fidvciary
ERISA-informed software that runs on your plan's actual claims data
The platform was designed with ERISA expertise and produces a report that tracks the DOL Self-Compliance Tool step for step.
Our process
You supply the inputs and your counsel signs the conclusions. Everything in between — the classification, the testing, the mapping to the DOL framework — is what the platform does.
Securely provide your plan documents and claims data — the 837/835 extracts from your TPA. The platform normalizes and classifies the data by benefit classification.
QTL substantially-all and predominant tests, NQTL denial-rate and prior-authorization disparity analysis by benefit classification, and the structured effects-test narrative — all mapped to the DOL framework.
You receive a complete, exportable report structured to the DOL Self-Compliance Tool. Your own counsel reviews the output in hours and adds the final legal conclusions.
What you get in a report
The deliverable is a complete, exportable comparative analysis structured 1:1 to the DOL Self-Compliance Tool. Every finding is traceable to your plan's data and to the methodology step that produced it.
Who it's for
Fidvciary is designed for self-funded employers of roughly 50 to 1,000 employees: large enough to carry real fiduciary exposure, small enough that a six-figure consulting engagement stalls at the CFO's desk.
We'd rather tell you now than waste your time. If you're unsure where your plan sits, a short call will settle it.
Cost
The traditional route is one bespoke engagement, billed at $10,000–$40,000 and delivered over two to four months. Fidvciary is a subscription that produces the analysis from your data in a fraction of the time and at a fraction of that cost. With quick turnover, the analysis stays current as your plan changes.
Positioned well below what a single manual engagement costs because the platform does the assembly your counsel would otherwise pay a consultant to do by hand.
Once your data is connected, the draft analysis is generated quickly, so the timeline is set by your attorney's review, not by a consultant's backlog.
Plans change. As a subscription rather than a one-off report, the analysis can be refreshed when your benefits, vendors, or utilization shift.
We don't publish a hard price because scope varies by plan. We'll walk you through it on a short discovery call.
Book a discovery callWhy trust the output
Fidvciary was built with deep ERISA and DOL-framework expertise, and the report is structured to the DOL Self-Compliance Tool: the same methodology a reviewer applies. That is the point. The strength of the analysis comes from tracing the government's own framework against your plan's real data, not from a proprietary black box.
The analysis follows the department's published framework rather than a proprietary checklist, so it maps directly to how the work is evaluated.
The platform was built by people who understand the statute and the comparative-analysis requirement, not a general-purpose compliance tool retrofitted for parity.
Claims data is sensitive. Our approach is encryption in transit and at rest, least-privilege access, and using your data solely to generate your analysis.
FAQ
Straight answers to the questions that decide whether this is worth a call (including the legal ones).
No. Fidvciary is a software platform, not a law firm. The analysis it generates is not legal advice and using Fidvciary does not create an attorney-client relationship. The platform produces a documented, data-driven comparative analysis; your own qualified counsel reviews it and is responsible for all legal conclusions.
Your plan documents (such as the plan document, SPD, and SBCs) and your claims and utilization data — typically the 837/835 extracts your TPA can provide. The platform normalizes and classifies this data by benefit classification so the testing can run against your plan's actual experience.
Once your data is connected, the platform generates the draft analysis quickly — the timeline is then driven by your attorney's review, which is typically measured in hours rather than the weeks a from-scratch engagement takes. Exact timing depends on the completeness of your data and your counsel's schedule.
Yes — by design. Fidvciary produces the analysis and the supporting documentation; your counsel reviews the output and renders the legal conclusions. The goal is to make your attorney's review faster and better-supported, not to replace it.
The Mental Health Parity and Addiction Equity Act requires that limitations a plan places on mental health and substance-use benefits are no more restrictive than those on medical and surgical benefits — and, since the 2024 final rule, that plans perform and document a comparative analysis of every non-quantitative treatment limitation. Enforcement and private litigation have escalated in parallel, which is why the requirement is now urgent for plan sponsors.
We treat claims data as the sensitive information it is. Our approach is encryption in transit and at rest, least-privilege access controls, and using your data solely to generate your analysis. Specific security terms are covered in your agreement before any data is shared.
Get started
Request a sample report to see exactly what the deliverable looks like, or book a short discovery call to talk through your plan and scope. No engagement required to look.
Prefer email? fidvciary@gmail.com