News & Analysis as of

Mental Health Parity Rule Department of Health and Human Services (HHS)

Neal, Gerber & Eisenberg LLP

Parity on Ice: MHPAEA’s 2024 Final Rule Heads to the Penalty Box

Federal regulators have paused enforcement of the 2024 Mental Health Parity and Addiction Equity Act (“MHPAEA”) Final Rule (the “2024 Final Rule”, published September 23, 2024) while they reconsider the rule and defend...more

Snell & Wilmer

Limited Mental Health Parity Relief for Plan Sponsors

Snell & Wilmer on

On January 17, 2025, the ERISA Industry Committee (“ERIC”) filed suit in the U.S. Court of Appeals for the D.C. Circuit asking the court to hold various key provisions under the 2024 Mental Health Parity Addiction Equity Act...more

Holland & Hart - The Benefits Dial

No Shoes, No Shirt, No Problems… But Nonenforcement Policy Doesn’t Make Mental Health Parity Compliance Optional

The Departments of Labor, Treasury, and Health and Human Services (the “Departments”) recently announced a nonenforcement policy with respect to the 2024 Mental Health Parity and Addiction Equity Act (“MHPAEA”) regulations or...more

Keating Muething & Klekamp PLL

Benefits Monthly Minute - May 2025

The May Monthly Minute brings you up-to-date on mental health parity enforcement relief, as well as smoker surcharge and prohibited transaction litigation. Nonenforcement of 2024 Mental Health Parity Regulations - Earlier...more

Groom Law Group, Chartered

Departments Pause Enforcement of MHPAEA Final Rule and Reconsider MHPAEA Enforcement Program

In a widely anticipated and welcome move, the Departments of Health and Human Services (“HHS”), the Treasury, and Labor (“DOL”) (collectively, the “Departments”), sought an abeyance of a lawsuit challenging the Mental Health...more

Warner Norcross + Judd

Delayed Enforcement of Mental Health Parity NQTL Comparative Analysis Final Regulations

Warner Norcross + Judd on

Under the Mental Health Parity and Addiction Equity Act (MHPAEA), as amended by the Consolidated Appropriations Act (CAA), 2021, group health plans and health insurance issuers must conduct comparative analyses to show that...more

Bricker Graydon LLP

Compliance Still Required During Non-Enforcement of 2024 Mental Health Parity Rule

Bricker Graydon LLP on

Last week, the Departments of Labor, Treasury, and Health and Human Services (the “Departments”)  issued a nonenforcement policy regarding the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA)  final regulations,...more

McDermott Will & Emery

Enforcement of Mental Health Parity Regulations Suspended: Takeaways for Plan Sponsors and Health Insurance Issuers

McDermott Will & Emery on

In January 2025, The ERISA Industry Committee (ERIC) filed a complaint against the US Departments of Labor, Health and Human Services, and the Treasury (the departments) seeking to invalidate the 2024 final regulations under...more

Foley & Lardner LLP

Mental Health Parity Alert - Non-Enforcement of Final Rules

Foley & Lardner LLP on

The Mental Health Parity and Addiction Equity Act (MHPAEA), and its implementing regulations and guidance, prohibits health insurance policies and group health plans that cover mental health and substance use disorder...more

Woodruff Sawyer

​​​​​​Agencies Push Pause Button on Enforcement of MHPAEA 2024 Final Rule

Woodruff Sawyer on

On May 15, 2025, the Department of Labor, Department of Health and Human Services, and the Treasury Department (collectively, the “Agencies”) released a statement regarding the Agencies’ recent request for abeyance of a...more

Polsinelli

Pressing Pause: Federal Agencies Halt Enforcement of Mental Health Parity Rule

Polsinelli on

On May 15, 2025, the Departments of Labor, Health and Human Services and the Treasury (the Departments) announced a non-enforcement policy regarding the final rule issued in September 2024 under the Mental Health Parity and...more

Ropes & Gray LLP

Tri-Agencies Stay Enforcement of the 2024 MHPAEA Final Rules

Ropes & Gray LLP on

On May 15, 2025, the Departments of Labor, Health and Human Services (“HHS”) and the Treasury (“the Departments”) issued a nonenforcement policy of the final rules under the Mental Health Parity and Addiction Equity Act of...more

Quarles & Brady LLP

Departments Will Not Enforce 2024 Final Rule under MHPAEA

Quarles & Brady LLP on

The Trump Administration has just announced that it will pause enforcement of the September 2024 final rule (“Final Rule”) under the Mental Health Parity and Addiction Equity Act (“MHPAEA”)....more

Seyfarth Shaw LLP

Parity in Peril? Plan Sponsors Breathe Easier As Trump Administration Hits Pause on Enforcement of Mental Health Parity Final Rule

Seyfarth Shaw LLP on

On May 15, 2025 the Departments of Labor, Health and Human Services, and Treasury (the “Departments”) announced they will temporarily not enforce their new standards published under the mental health parity Final Rule last...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Regulators Pause Mental Health Parity Rules Enforcement

Federal regulators recently indicated they will not enforce parts of the final regulations issued in September 2024 under the Mental Health Parity and Addiction Equity Act (MHPAEA) and may soon propose new rules altogether....more

Jackson Lewis P.C.

UPDATE – Departments issue nonenforcement policy statement!

Jackson Lewis P.C. on

On May 15, 2025, the Departments of Labor, Treasury, and Health and Human Services issued their anticipated nonenforcement policy regarding the 2024 Mental Health Parity regulations. As expected, nonenforcement is applicable...more

Proskauer - Employee Benefits & Executive...

Departments Press Pause on Final Mental Health Parity Regulations

Yesterday, the Departments of Labor, Treasury, and Health and Human Services announced a non-enforcement policy with respect to final regulations issued under the Mental Health Parity and Addiction Equity Act of 2008...more

Woodruff Sawyer

Critical Compliance Issues for Employee Benefits in 2025

Woodruff Sawyer on

With a new presidential administration in place and various reforms already underway, the landscape of employee benefits compliance is poised for significant changes. To help organizations prepare, Woodruff Sawyer hosted a...more

Husch Blackwell LLP

Litigation Looms: ERIC Seeks Stay on 2024 Mental Health Parity Rule Enforcement

Husch Blackwell LLP on

On February 20, 2025, the ERISA Industry Committee (ERIC) announced that its legal counsel submitted a letter to the U.S. Departments of Labor (DOL), Health and Human Services (HHS) and Treasury, requesting a stay of...more

McDermott Will & Emery

Complying With the ‘Relevant Data’ Requirement Under the Final 2024 Mental Health Parity and Addiction Equity Act: A Proposal for...

McDermott Will & Emery on

The Mental Health Parity and Addiction Equity Act (MHPAEA) generally requires group health plans and health insurance issuers to ensure that financial requirements (such as copays and deductibles), quantitative treatment...more

Alston & Bird

2024 Health Benefits Year: A Year to Remember

Alston & Bird on

The year was packed with developments for health and welfare benefits plans. Our Health Benefits Team reviews 2024, from new data privacy rules to disaster tax relief....more

Quarles & Brady LLP

Final Rule under MHPAEA Clarifies NQTL Comparative Analysis Requirement

Quarles & Brady LLP on

On September 23, 2024, the Departments of Labor, Treasury, and Health and Human Services (together, “Departments”) issued a final rule (“Final Rule”) under the Mental Health Parity and Addiction Equity Act (“MHPAEA”). The...more

Alston & Bird

Final Mental Health Parity Rules: A Plan Sponsor’s Implementation Guide

Alston & Bird on

Our Employee Benefits & Executive Compensation Group discusses what health plan sponsors need to know about the final rule on nonquantitative treatment limitations (NQTLs) and NQTL comparative analysis under the Mental Health...more

Arnall Golden Gregory LLP

New Federal Parity Rules: A Step Forward for Equitable Mental Health and Substance Use Disorder Coverage

In September 2024, the U.S. Departments of Labor, Health and Human Services, and the Treasury (collectively, “the Departments”) released final rules to strengthen the enforcement of the Paul Wellstone and Pete Domenici Mental...more

BCLP

Mental Health Parity Final Rule Imposes Year-end Action Items on Group Health Plan Sponsors

BCLP on

On September 9th, the Department of Health and Human Services, the Department of Labor, and the Department of the Treasury (collectively, the “Departments”) issued the much anticipated final rule under the Mental Health...more

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