2024 MHPAEA Final Rule

The 2024 MHPAEA Final Rule (89 FR 77586), issued in September 2024, significantly expanded NQTL requirements, required outcomes-based comparative analyses, and added network adequacy standards for MH/SUD benefits. On May 15, 2025, the Departments of Labor, HHS, and Treasury issued a joint statement announcing non-enforcement of the 2024 rule's core NQTL provisions pending resolution of ERISA Industry Committee v. DOL. However: (1) the 2013 Final Rule remains in force; (2) the CAA 2021 § 203 disclosure obligation is unaffected; and (3) state parity laws in CA, NY, MA, IL, OR, WA, and CO have adopted independent standards that may exceed the 2013 federal floor.