Three years after the Consolidated Appropriations Act of 2021 mandated that group health plans perform comparative analyses of non-quantitative treatment limitations (NQTLs), enforcement is finally catching up to the requirement — and most plans are not ready. This piece walks through the four most common failure modes we see in NQTL analyses, the documentation that regulators are now requesting on first inquiry, and the structural shifts plan sponsors should be making before the next plan year.