BenefitsPRO August 23, 2023
As employers and their advisors are gearing up for 2024 open enrollment, major mental parity changes are looming on the horizon.
Newly proposed rules would, starting in 2025, present a major challenge to completing the written “comparative analysis” that every plan has needed since 2022 to demonstration compliance with a key requirement of the federal mental health parity rules. That comparative analysis requirement comes from the Consolidated Appropriations Act, 2021 (“CAA”).
Federal regulators will take comments on these new proposals until October 2, 2023, so significant revisions are possible in these rules under the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008 (“MHPAEA”). But, for now, we think it is important for employers and...