Every health plan is required to prove its mental-health and addiction benefits are no more restrictive than its medical and surgical benefits — and to produce the documented analysis on demand. This is the whole model in five steps: the obligation, the framework, the side-by-side comparison, the report you receive, and what it changes. Follow one limitation from input to documented finding.
Federal parity law requires every health plan to prove that its mental-health and substance-use benefits are no more restrictive than its medical and surgical benefits — not only in the plan document, but in operation. How long does approval take? How often are claims denied? Who makes the decision? Each of those comparisons must be documented for every non-quantitative treatment limitation, in every benefit classification, and produced for the Department of Labor on demand.[1]
The problem is that almost no one can produce it correctly. Across four consecutive DOL Reports to Congress, not a single NQTL comparative analysis was found sufficient on first review.[2] Plans hire consulting firms at an estimated $150,000 to $500,000 per engagement[3], wait months, and receive a binder that still fails. The scale is the reason.
Think of it as TurboTax for parity compliance. You enter your plan's own operational data — prior-authorization rules, denial rates, network standards, clinical criteria. Equipoise structures every analysis around the six elements the Consolidated Appropriations Act of 2021 requires[4], so all six are prompted for and each maps to a specific regulatory citation. Pick one of 9 NQTL categories across 6 benefit classifications — up to 54 comparison points per plan[1] — and the engine loads the comparison factors specific to that limitation.
The limitation, the plan language that defines it, and the benefits affected.
The variables used to decide how and when the limitation applies.
The evidence and sources supporting each factor.
MH/SUD against medical/surgical, as written and in operation.
Whether the limitation complies, with the reasoning shown.
Corrective actions when the analysis finds non-compliance.
Equipoise does not pull your data from a payer system — you enter it, the way TurboTax doesn't pull your W-2 from payroll. The analysis, the cross-referencing, the gap identification, and the documentation: that is what the software does.
The engine sets the MH/SUD arm against the medical/surgical arm and evaluates each factor for the same limitation — both as written and in operation. Where MH/SUD is more stringent in the plan language or in the outcome data, it is flagged, and the finding cites the provision that governs it. The example below is a specimen: prior authorization, inpatient, commercial.
Specimen values, shown for illustration. In the live tool every cell links to the data you entered and the regulation that governs it.
Each finding carries the specific disparity, the regulatory citation, and a recommended corrective action with owners, deadlines, and status. Equipoise assembles them into a documentation-ready report formatted for DOL standards, with a fiduciary attestation step. The deliverable is the compliance artifact itself — the thing a plan has to produce on demand.
Every finding is documented, every disparity cited, and the whole analysis is exportable for ERISA-counsel review before submission. Equipoise stores no protected health information — inputs are aggregate plan-level operational metrics.
When the examiner asks for your analysis, you hand them a methodology built on the same six-element framework they use to evaluate it — for a fraction of one consulting engagement, in minutes per NQTL rather than months. And the obligation has not gone anywhere: although the tri-Departments said in May 2025 they will not enforce or defend the 2024 Final Rule, the underlying statutory requirement under parity law and the 2013 rule remains fully in effect, private suits and DOL audits run on it, and states are enforcing independently — Georgia alone imposed more than $25 million in parity fines in 2025.[5]
Equipoise is built by Joe Nalley, who ran a 13-location integrated health system — including behavioral health and SUD/MAT — as CEO through acquisition, founded and sold ClearBill, which returned $9.2 million to payers in its first six months of full deployment, and is today Staff Vice President of Carelon Growth (Elevance Health), owning six high-acuity clinical risk books across $50B+ in specialty medical spend.[6] The engine implements the DOL's six-element framework as defined in 29 CFR 2590.712(c)(4), with the citations checked against the regulatory text and the Reports to Congress, and re-checked as guidance changes.