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 Rule implementing the Mental Health Parity and Addiction Equity Act (MHPAEA). As part of the request, the Departments indicated that they will suspend enforcement of the 2024 Rule.
The 2024 Rule was issued to implement revisions to the MHPAEA statute that were passed as part of the Consolidated Appropriations Act of 2021 (“CAA”) to add specific requirements for the development and enforcement of comparative analyses for non-quantitative treatment limits (“NQTLs”). The Departments’ enforcement suspension was announced as a part of a motion to hold in abeyance a legal challenge to the statutory basis for the 2024 Rule that was filed by the ERISA Industry Committee (“ERIC”) on January 17, 2025.
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