Michigan Law

Mental Health Parity and ABA Coverage

Whether ABA is treated as a mental health benefit for parity depends on how the plan classifies it.

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The details

What parity requires

The rule

Group health plans and issuers that provide mental health or substance use disorder benefits generally may not impose less favorable benefit limitations on them than on medical and surgical benefits.

Quantitative limits

This includes quantitative treatment limits such as age and dollar caps.

Non-quantitative limits

Plans must be able to show processes and standards for non-quantitative limits are comparable. The Consolidated Appropriations Act, 2021 added comparative analysis requirements.

Classification

How a plan classifies ABA affects whether parity applies. Ask counsel.

Back to the ABA guide.

Questions We Get

Mental Health Parity and ABA Coverage: short answers

Does parity apply to self-funded plans?

Yes, it is federal law and applies to group health plans, subject to its exemptions.

Is parity the same as the autism mandate?

No. Parity compares benefits. The mandate requires specific coverage.

Where is our parity guide?

Our Michigan mental health parity guide covers it.

Mental Health Parity and ABA Coverage: not legal advice. Send us your renewal.

Sources

Where these details come from

The laws and rules named on this page link to the official text. This is general information, not legal advice, and rules change, so check the current text.

CMS: Mental Health Parity and Addiction Equity Act

U.S. Departments of Labor, HHS and Treasury: 2025 parity enforcement statement

Autism Speaks: Michigan state-regulated insurance coverage

Let’s Get to Work

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What to send

The renewal letter
Your current plan summary
Contribution split by tier
Enrolled counts by tier

Four documents — two more if your group is 50 or more. Nothing else; every extra one is a reason to postpone.

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