The Employee Retirement Income Security Act of 1974 (ERISA) is a primary federal law that governs employee benefit plans, including group health and welfare plans. ERISA imposes significant fiduciary, disclosure and reporting obligations on covered plans.

The Consolidated Appropriations Act, 2021 (CAA) created an additional compliance obligation for plans that are subject to the Mental Health Parity and Addiction Equity Act (MHPAEA). Specifically, the CAA requires plans and insurance carriers to report how the nonquantitative treatment limitations imposed on mental health and substance use disorder benefits are in parity with those imposed on medical/surgical benefits.