
On Sept. 9, 2024, the Departments of Labor, Health and Human Services, and the Treasury (Departments) released a final rule to strengthen the requirements of the Mental Health Parity and Addiction Equity Act (MHPAEA). The final rule is designed to ensure that individuals do not face greater restrictions to obtaining mental health and substance use disorder (MH/SUD) benefits than they would face for medical/surgical benefits.
The final rule adds protections against more restrictive nonquantitative treatment limitations (NQTLs), such as preauthorization requirements and network composition standards. For example, the final rule requires group health plans and health insurance issuers to collect and evaluate data related to the NQTLs they place on MH/SUD care and make changes if the data shows they are providing insufficient access.
The final rule also establishes minimum standards for developing comparative analyses to assess whether NQTLs comply with MHPAEA’s requirements. In most cases, employers rely on issuers and third-party vendors to prepare comparative analyses for their health plans. However, the final rule requires the comparative analyses for health plans covered by ERISA to include a fiduciary’s certification that they have engaged in a prudent process and monitored their service providers.
The final rule generally applies for plan years beginning on or after Jan. 1, 2025; however, certain key requirements, such as NQTL data requirements, apply for plan years beginning on or after Jan. 1, 2026.
Contact us to see how you could minimize risk:
Recent News
How an Extra Biweekly Payroll Period in 2026 Impacts Payroll
For employers that run biweekly payroll, 2026 introduces a unique scheduling challenge.
Employee Spotlight: Lane Trust
Please help us welcome Lane to the Seubert Team as a Strategic Risk Advisor!
Employers Should Prepare for 2026 RxDC Reporting
Group health plans and health insurance issuers must annually submit detailed information on prescription drug and health care spending to the CMS.
DOL Announces Proposed Independent Contractor Rule
The DOL announced a proposed rule to rescind its 2024 final independent contractor rule and replace it with an analysis of employee classification under the FLSA.
Improving the Effectiveness of Cybersecurity Training
Workforce cybersecurity training is a critical part of a company’s security risk management program.
Stop-Loss Insurance: A Critical Tool in Today’s Employee Benefits Strategy
Rising healthcare costs, catastrophic claims, and specialty drug spend are driving increased reliance on stop-loss insurance — making it a critical component of modern employee benefits and risk management strategies.

