Enforcement of the 2024 final regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA) has been suspended due to litigation by The ERISA Industry Committee. In response, the US Departments of Labor, Health and Human Services, and Treasury announced that they will not enforce the new rule until the case is resolved, plus an additional 18 months.
The suspension provides temporary relief from several burdensome requirements in the 2024 Final Rule, such as the “relevant data requirements” (which generally required parity in outcomes), the controversial “meaningful benefit” test, and fiduciary certification mandates. However, plan sponsors must still comply with MHPAEA’s core obligations and the requirements of the Consolidated Appropriations Act, 2021, including the written nonquantitative treatment limitation comparative analysis.
