News & Analysis as of

Mental Health Enforcement Actions

Cozen O'Connor

NY AG Puts Mental Health Ghost Network to Rest

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New York AG Letitia James has announced an agreement with MVP Health Plan (MVP) following an investigation that found systemic problems with the insurer’s mental health provider network. The investigation revealed that MVP’s...more

Hudson Cook, LLP

Texas AG Opens Investigation into AI Developers for Allegedly Misleading Children with AI-Generated Mental Health Services

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On August 18, 2025, Attorney General Ken Paxton announced the opening of an investigation into two artificial intelligence (AI) developers for potential deceptive trade practices and misleading marketing. According to the...more

Kelley Drye & Warren LLP

Highlights from the 2025 NAAG Presidential Summit

In early August, the National Association of Attorneys General, led by its 2025 President, New Hampshire Attorney General John Formella, hosted the Presidential Initiative Summit in Portsmouth, New Hampshire. General...more

DLA Piper

A Legislative and Enforcement Outlook for Mental Health Chatbots

DLA Piper on

A concept once confined to speculative and science fiction, artificial intelligence (AI) therapists – in the form of online chatbots – now exist and are available for use in the present day. Some of them have been developed...more

Robinson+Cole Data Privacy + Security Insider

Illinois Enacts Act Prohibiting AI Therapy

On August 4, 2025, Illinois Governor JB Pritzker signed the Wellness and Oversight for Psychological Resources Act into law, which went into immediate effect, and “prohibits anyone from using AI to provide mental health and...more

Akin Gump Strauss Hauer & Feld LLP

Ending Crime and Disorder on America’s Streets (Trump EO Tracker)

Directs federal agencies to support the expanded use of civil commitment and institutional treatment for homeless individuals with serious mental illness or substance use disorders, while conditioning federal grants on the...more

Buchalter

9th Circ. Decisions Help Clarify Scope Of Legal Lab Marketing

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The Eliminating Kickbacks in Recovery Act, enacted in 2018, was a bombshell for the addiction treatment and diagnostic laboratory industries. For the first time, paying commissions for sales and marketing services was...more

Foley & Lardner LLP

Gender-Affirming Care: Key Takeaways from FTC’s July 2025 Workshop on Unfair Or Deceptive Trade Practices

Foley & Lardner LLP on

On July 9, 2025, the Federal Trade Commission (FTC) hosted a workshop focused on perceived “dangers” arising from unfair or deceptive trade practices in marketing a variety of health care services falling under the label of...more

Wiley Rein LLP

FTC Reviews Its Approach to Kids’ Online Activity – What Comes Next?

Wiley Rein LLP on

The Federal Trade Commission (FTC) recently hosted a workshop on kids’ online activity, titled “The Attention Economy: How Big Tech Firms Exploit Children and Hurt Families.” Speakers included two U.S. Senators, all three FTC...more

Stoel Rives - Health Law Insider®

In Case You Missed It: Federal Agencies Pause Enforcement of the 2024 MHPAEA Final Rule; Prior Regulations and Comparative...

On May 15, the U.S. Departments of Labor, Health and Human Services, and the Treasury (“the Departments”) released a statement announcing a temporary non-enforcement period regarding their final rule issued on September 9,...more

Littler

The Parity Paradox: MHPAEA Compliance for Employers and Insurers During the 2024 Enforcement Pause

Littler on

The U.S. Departments of Labor, Health and Human Services, and Treasury have announced that they will pause enforcement of the 2024 Mental Health Parity and Addiction Equity Act (MHPAEA) Final Rule (the “2024 Final Rule”) for...more

Bond Schoeneck & King PLLC

Administration Grants Welcome Reprieve From Certain NQTL Requirements

Administration Grants Welcome Reprieve From Certain NQTL Requirements - Earlier this month, the Departments of Labor, Health and Human Services and Treasury (the “Departments”) announced that for the foreseeable future...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

Perkins Coie

New Utah AI Laws Change Disclosure Requirements and Identity Protections, Target Mental Health Chatbots

Perkins Coie on

Key Takeaways - - Utah has introduced five new bills that further shape its existing Artificial Intelligence Policy Act and add new requirements. - Both the scope of disclosure requirements surrounding the use of AI...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

Morgan Lewis - ML Benefits

Mental Health Parity Non-Enforcement Statement Released

The US Departments of Labor, Health and Human Services, and the Treasury (the Departments) announced their non-enforcement policy on May 15, 2025, indicating they will not enforce any new requirements imposed by the...more

Jackson Lewis P.C.

A Bit of Mental Health Parity Relief for Employers Sponsoring Group Health Plans

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The Department of Labor (DOL), together with the Departments of Treasury and Health and Human Services) have decided to suspend enforcement of certain provisions of the nonquantitative treatment limitations (NQTL) final...more

Epstein Becker & Green

Federal Regulators Announce Non-Enforcement of the 2024 Rule for Mental Health Parity

Epstein Becker & Green on

On May 9, 2025, the Departments of Labor, Health and Human Services, and Treasury (collectively, “the Departments”) asked the D.C. federal court to suspend litigation while they consider whether to rescind or modify the 2024...more

Holland & Knight LLP

Religious Institutions Update: May 2025

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Federal Trade Commission Protects Worship Location Data Shannon Britton Hartsfield and Bess Hinson-Greenspan Recent Federal Trade Commission (FTC) enforcement activity signals that companies need to protect consumer location...more

McGuireWoods LLP

DOJ Targets Neurofeedback Billing in $15 Million Behavioral Health Fraud Case

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On March 6, 2025, federal prosecutors charged a Minnesota couple — Gabriel Adam Alexander Luthor and Elizabeth Christine Brown — with orchestrating a $15 million healthcare fraud scheme involving overbilling and submission of...more

Cozen O'Connor

NAAG Attorney General Symposium Recap

Cozen O'Connor on

Between April 7 and 9, 2025, the National Association of Attorneys General held its annual Attorney General Symposium in Nashville, Tennessee. State AGs, attorney general staff, and private sector attendees heard from leaders...more

Arnall Golden Gregory LLP

Challenges in Enforcing Mental Health Parity: EBSA’s Struggle to Ensure Compliance

A recent audit conducted by the U.S. Department of Labor’s Office of Inspector General (“OIG”) has uncovered significant challenges encountered by the Employee Benefits Security Administration (“EBSA”) in ensuring compliance...more

Troutman Pepper Locke

Vermont AG Clark Secures $2.7M Judgment Against Mental Health Counselor

Troutman Pepper Locke on

On February 4, a Vermont Superior Court judge entered a $2,733,989.47 judgment against Phoenix Counseling & Wellness, PLC (Phoenix), and the company’s owner for alleged violations of the Vermont False Claims Act (VFCA)....more

Health Care Compliance Association (HCCA)

[Event] Regional Healthcare Compliance Conference - November 1st, Scottsdale, AZ

Looking for compliance education and networking in your area? HCCA’s Regional Healthcare Compliance Conferences offer practitioners convenient, local compliance education on a wide variety of current and emerging topics...more

Mintz - Health Care Viewpoints

Health Care Privacy and Security In 2024: Six Critical Topics to Watch

As we reflect on the flurry of activity in the health care data privacy and security space in 2023 and look ahead to what will continue to be a busy 2024, we are seeing the early stages of federal agency movement to align the...more

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