Whether ABA is treated as a mental health benefit for parity depends on how the plan classifies it.
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.
This includes quantitative treatment limits such as age and dollar caps.
Plans must be able to show processes and standards for non-quantitative limits are comparable. The Consolidated Appropriations Act, 2021 added comparative analysis requirements.
How a plan classifies ABA affects whether parity applies. Ask counsel.
Back to the ABA guide.
Yes, it is federal law and applies to group health plans, subject to its exemptions.
No. Parity compares benefits. The mandate requires specific coverage.
Our Michigan mental health parity guide covers it.
Mental Health Parity and ABA Coverage: not legal advice. Send us your renewal.
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
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