Alert: Sweeping mental health parity rules add new requirements 

September 13, 2024

Significantly revised Mental Health Parity and Addiction Equity Act rules may require employer action before Jan. 1, 2025. Most content requirements for the comparative analysis of nonquantitative treatment limitations (NQTLs) — including certification by a plan fiduciary — apply for plan years beginning on or after Jan. 1, 2025. Changes to parity standards aimed at improving access to services for mental health and substance use disorders by focusing on benefit coverage and network adequacy take effect for plan years beginning on or after Jan. 1, 2026.

Although litigation challenging these rules is expected, employers sponsoring self-insured plans should consider reviewing and revising their NQTL comparative analyses and identifying the appropriate fiduciary to complete the certification before the 2025 plan year.

Download the 11-page print-friendly PDF to read details about the revised regulations.