MD| Maryland’s Insurance Administration bulletin 26-12 extends the 2026 filing deadline and updates the required format and scope for non-quantitative treatment limitation (NQTL) mental health and substance use disorder parity reports, clarifying that carriers must rely on pre–Senate Bill 205 § 15-144 for this cycle while still encouraging voluntary submission of data reflecting the recent amendments. Carriers must submit product-level NQTL reports (rather than plan-level for the top five plans), electronically by encrypted email by September 1, 2026, using only the Commissioner’s finalized 2026 instructions and standardized data supplement templates based on calendar year 2025 data, and including comparative analyses of five specified NQTLs plus a signed officer attestation that the NQTLs and their governing processes and factors are consistent across all plans in each product or, if not, separate analyses for any exceptions. Although the new statutory requirements from Senate Bill 205 effective July 1, 2026 are not incorporated into the 2026 templates, the MIA encourages carriers to voluntarily submit data aligned with those amendments, and reminds carriers that they still must identify, analyze, and document all NQTLs for mental health and substance use disorder benefits and provide those analyses upon request, with failure to file or respond timely constituting noncompliance with the Parity Act.
Key Points:
- Filing deadline extended from July 1, 2026, to September 1, 2026, with secure electronic submission and use of MIA-issued NQTL report forms, instructions, and 2026 data templates based on 2025 data.
- Reports must be completed at the product level and include comparative analyses of five designated NQTLs, supported by standardized data supplements and a corporate officer’s attestation regarding the uniform design and application of NQTLs across plans.
- For 2026, carriers should follow § 15-144 as it existed before Senate Bill 205, but are encouraged to voluntarily provide data using the amended definitions and outcome metrics, while remaining obligated to maintain and furnish complete comparative analyses of all NQTLs upon request.