The U.S. Departments of Health and Human Services, Labor, and the Treasury recently released much-anticipated final rules implementing the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA). These new rules will begin to take effect on January 1, 2025, giving employer health plans a limited amount of time to navigate a range of compliance challenges. In this legal update, Ogletree Deakins attorneys Carly Grey, Tim Stanton, and Hillary Sizer will discuss the updated “meaningful benefit” standard, the requirement for a plan fiduciary to sign a statement related to the legally required “comparative analysis” of nonquantitative treatment limitations, and the new data analysis requirements set to take effect in 2026.

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