On September 8, 2026, the Department of Labor’s Employee Benefits Security Administration (“EBSA”) issued Field Assistance Bulletin No. 2026-03 (the “FAB”), outlining a new set of guiding principles for enforcing the nonquantitative treatment limitation (“NQTL”) requirements under the Mental Health Parity and Addiction Equity Act (“MHPAEA”), as amended by the Consolidated Appropriations Act, 2021 (“CAA