In connection with litigation challenging the validity of 2024 regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA), the DOL, HHS, and IRS have announced that they are reconsidering the regulations, including whether to rescind or modify the provisions through future rulemaking. The 2024 regulations amended 2013 MHPAEA regulations by expanding compliance obligations to include, among other things, extensive evaluation of outcomes data and adherence to a “meaningful benefit requirement,” that, according to the challengers, is effectively a benefits mandate that the agencies are not authorized to impose. Explaining that the agencies have asked the court to put the lawsuit on hold, the statement provides that the agencies will not enforce the 2024 regulations or otherwise pursue enforcement actions based on compliance failures that occur before a final decision in the litigation, plus an additional 18 months. The enforcement relief applies only to those portions of the 2024 regulations that are new in relation to the 2013 regulations, and the statutory obligations of MHPAEA, as amended by the CAA, 2021 (including the comparative analysis requirement) remain in effect.
To dig deeper, visit the original article on the Thomson Reuters blog.