Lexology September 27, 2024
Seyfarth Shaw LLP

Seyfarth Synopsis: On September 9, 2024, the Departments of the Treasury, Labor, and Health and Human Services (the “Departments”) released highly anticipated Final Rules under the Mental Health Parity and Addiction Equity Act (MHPAEA). Instead of providing the guidance hoped for by stakeholders, the new rules may leave employers wondering if they should continue to offer mental health (MH) and substance use disorder (SUD) benefits.

In a prior alert, we described how proposed regulations would amend existing regulations under MHPAEA and what would be required for group health plans that apply non-quantitative treatment limitations (NQTLs) to MH and SUD benefits. The Final Rules both add requirements and modify the requirements set forth in the proposed regulations.

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The Final Rules...

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