One method that satisfied a DOL inquiry was a side by side factor mapping of the NQTL to medical surgical comparators using a single standardized matrix. We documented the precise factors used to design and apply prior authorization for MH SUD and showed the same factors, evidentiary standards, and thresholds were used for analogous medical benefits. What made it pass muster was evidence, not narrative. We attached the criteria source documents, utilization management policies, approval rates, denial rationales, and a decision tree showing operational application. The template forced parity across design, application, and outcomes, which addressed the DOL focus on how the NQTL actually operates in practice. Albert Richer, Founder, WhatAreTheBest.com