42 Compliance with the Mental Health Parity and Addiction Equity Act The Mental Health Parity and Addiction Equity Act and regulations issued thereunder (“MHPAEA”) generally require that the Plan may not impose a financial requirement or treatment limitation on any mental health/substance use disorder benefits offered under the Plan unless the requirement or treatment limitation meets certain requirements, as documented by a comparative analysis. Certain components of the Care Coordination Program, including the Prior Authorization and Concurrent review requirements and the use of other “Medical Management Standards” (medical experimental or investigative treatment to make benefit determinations) are generally considered Non- Quantitative Treatment Limitations (NQTLs) under MHPAEA. The Care Coordination Program is intended to be compliant with the MHPAEA in its design and application because: • The Plan’s Prior Authorization and Concurrent review and Medical Management Standards are reasonably designed to detect or prevent fraud, waste and abuse. • The processes, strategies, evidentiary standards and other factors used to design the Prior Authorization, Concurrent review and Medical Management Standards requirements for mental health or substance use disorder benefits in each classification are comparable to and no more restrictive than those processes, strategies, evidentiary standards, or other factors used to design the Prior Authorization, Concurrent review and Medical Management Standards to substantially all of the medical and surgical benefits in the same classification as reflected above. • The clinical criteria applied by the Plan under the Medical Management Standards as written and in operation for medical/surgical and mental health/substance use disorder benefits are generally recognized independent professional medical or clinical standards (generally, InterQual, the TPA’s medical criteria and Quantum Health medical director criteria consistent with generally accepted standards of care). The Plan’s Prior Authorization, Concurrent review and Medical Management Standards, as written and in operation, are not applied to mental health or substance use disorder benefits in any classification more restrictively or more stringently than and are impartially applied comparably to the Prior Authorization, Concurrent review and Medical Management Standards applied to substantially all medical/surgical benefits in the same classification.