MHPAEA Final Rule · Effective 2025

Clarity into every denial. A filed-ready appeal in 90 seconds.

OnClarity reads the denial, the plan, and the MHPAEA Final Rule, then drafts an appeal that cites the rule by section. Bolt-on to SimplePractice, TherapyNotes, TheraNest. No EHR switch.

§A

Downcoding

NQTL: medical-necessity criteria.

§B

Visit cap

Concurrent review tighter than comparable medical.

§C

Missing analysis

Final Rule §2590.712-1(c)(6).

Aetna · EOB 835 · Claim 4791-A

04/22/2026

Statement of Denial

Member: J. R. · NPI 1538204417 · DOS 04/15/2026

90837Psychotherapy, 60 min$185.00

The above service has been ^Adowncoded to 90834 on the basis of medical-necessity criteria. Concurrent review will be required for ^Bany additional sessions exceeding twenty in calendar year.

Reason code: CARC 197 · Remark: RARC N115. ^CNo comparative analysis on file.

Member responsibility: $185.00 · Plan paid: $0.00.

Plan: Aetna Choice POS II · Group 80214

Denied

Built by operators from

75%

of appealed mental-health denials get overturned.

Source · KFF · AMA

<1%

of denials are ever appealed. Most are walked away from.

Source · KFF

2–3×

behavioral-health denial rates run higher than medical.

Source · KFF · SimiTree

§01 · The shift

The 2024 MHPAEA Final Rule changed what a denial is allowed to look like.

For decades, mental-health benefits failed parity quietly. The Final Rule, effective 2025, changed the rules of evidence.

Payers now have to perform a comparative analysis on every non-quantitative treatment limitation. Visit caps. Concurrent review. Medical-necessity criteria. Fail-first rules.

“If a payer applies a limit to mental health that is more restrictive than the comparable medical limit, the denial is probably out of compliance.”

Most therapists do not know this happened. Most denials never get appealed. We make appealing the obvious move.

How it works

§02 · Forward → Test → File

Forward the denial.

Drop the EOB, the 835, or a screenshot. We parse the CARC and RARC codes.

CARC 197 · RARC N115

We run the parity test.

DOL framework applied to the payer's own published criteria. We name the non-quantitative limitation. We cite the section.

26 CFR §54.9812-1

You get a filed-ready appeal.

The letter quotes the rule. It is in the right format for the payer's portal. You sign. Send.

Aetna · UHC · BCBS · Cigna

What makes it different

§03 · The lane

	OnClarity	Counterforce	Your EHR	Healthcare attorney
Built for therapists			partial
Cites MHPAEA Final Rule by section
Knows your top 4 payers				manual
Cost per appeal	$0–15	free, limited	bundled, no appeals	$300–500/hr

HIPAA-aware architecture·BAA on every paid plan·MHPAEA Final Rule (Sep 2024) referenced in every appeal·Federal Register·DOL Self-Compliance Tool

§04 · FAQ

The questions therapists actually ask.

No. Your EHR tracks claims. OnClarity argues with them.

No. We generate a citation-grade draft. You review, you sign, you send. We are not your attorney.

Counterforce is built for patients fighting their own denials. OnClarity is built for the people who file the claims in the first place. Different audience, different appeal language, different workflow.

Roughly 60% of the appeal value comes from straightforward CARC/RARC citation work that survives any rule change. We were not built on a single statute.

No. Flat monthly. Headway and Alma take 30-50% on every claim. We charge less than 1% of one therapist's monthly Medicare ceiling.

§05 · Book a call

The payer does not get to be the only one who has done the math.

15 minutes. No card. No commitment.