What you need to know

As previously communicated, Prime is committed to supporting compliance efforts with the Mental Health Parity and Addiction Equity Act (MHPAEA) and helping facilitate access to effective mental health and addiction treatment. As an industry leader in Mental Health Parity (MHP), Prime developed standardized suites of Non-Quantitative Treatment Limitation (NQTL) Comparative Analyses (CAs), which are now available to clients. 

Prime’s leadership in mental health parity 

Prime approaches MHP as an enterprise priority, driven not by regulatory pressure, but by a commitment to doing what is right for our clients. We have invested in a dedicated MHP governance structure that unites executive, clinical, compliance, legal and operational leaders to ensure our parity initiatives are consistent, defensible and aligned with the evolving regulatory landscape. 

In addition to working directly with clients to support real-world parity outcomes, Prime’s MHP experts have engaged nationally. Recently, Prime shared insights at the Academy of Managed Care Pharmacy’s (AMCP) 2026 Annual Conference. Prime also partnered with a major health plan to help it become one of the first organizations to earn the Utilization Review Accreditation Commission’s (URAC) Mental Health and Substance Use Disorder Parity Accreditation.  

Prime’s standard NQTL Comparative Analysis offering 

Prime delivers NQTL Comparative Analyses (CAs) and MHP support for prescription and medical benefit drugs to strengthen regulatory readiness, reduce clients’ administrative burden and foster transparent partnership. Prime’s NQTL CA document suites include narrative” templates and associated client-specific data reports that are intentionally designed for defensible audit preparedness and reduce the need for clients to independently develop pharmacy benefit evidence.  

For most clients, Prime’s CAs cover up to four NQTL areas: Formulary Design and Tiering, Prior Authorization, Step Therapy and Quantity Limits. For medical benefit drugs, Prime prepares an NQTL CA for Utilization Management.  

Prime’s approach 

• Prime fulfills annual NQTL CAs for each unique client configuration. The standard report scope period is the previous full calendar year (e.g. requests submitted in 2026 include data from Jan. 1, 2025, through Dec. 31, 2025). 
• To support the evaluation of real-world parity outcomes, Prime provides a standardized data report that includes formulary and coverage determination information, utilization tables that interpret and organize the underlying data and a detailed description of the report logic and methodology. By delivering a comprehensive set of raw data, Prime enables client organizations to maintain transparency and perform independent analyses, including subpopulation evaluations and the creation of customized reporting views. 
• Prime analyzes the totality of the evidence and makes a recommendation for parity “as written” and “in operation” for each NQTL. In the event of apparent non-parity, Prime will investigate the cause and provide an explanation. 
• The client organization can adapt Prime’s documents as appropriate or use them without modification. 
• The client organization retains responsibility for the final content, accuracy and completeness of its NQTL CA and any related submissions. 
• Requests that fall outside Prime’s established standards may be considered custom, and depending on contract terms, may be subject to extended timelines and/or additional fees. 
• Prime expects to have finalized the 2026 NQTL CA document suites by April 1, 2027. 

How to request MHP reporting 

• Clients integrated into Salesforce: Clients can submit a Salesforce ticket for NQTL CAs and/or other MHP-related reporting. Mental Health Parity Support is located under the “Other” reporting category.  
  • The request form will prompt the requester to complete all required fields, as well as carrier IDs and formulary IDs (FIDs) needed for the analysis and inclusion/exclusion of protected health information (PHI). 
  • If using a client-specific mental health/substance use disorder (MH/SUD) drug list, it must contain GPI-14 values and be attached to the ticket.  
• Clients not integrated into Salesforce: Clients can contact their Prime client account team for NQTL CAs and/or other MHP-related reporting requests.
  • Provide carrier IDs, lines of business, all formulary IDs needed for the analysis, and a statement to include or exclude PHI.  
  • If using a client-specific MH/SUD drug list, it must contain GPI-14 values and be attached to the request. 

This standardized approach allows Prime to improve turnaround times and consistency across analyses for our clients. We leverage clinical, compliance and operational expertise to support our clients with MHP reviews, audits and regulatory engagements. 

Next steps 

Mental Health Parity regulations continue to evolve, and Prime remains committed to leading with transparency, accountability and purpose — supporting client compliance today while advancing equitable access to care for the members we collectively serve. 

In the event of a regulatory audit, Prime will provide subject matter expertise and support for matters related to the prescription drug benefit. 

To support parity compliance, drug policies with utilization management strategies now contain an NQTL Factor Checklist, which you can request from your Prime client account team. 

Questions 

For questions about the NQTL CA templates or data report workbooks, please use the Chatter function in Salesforce or contact your Prime client account team.