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ARTICLE · 22 MAY 2025

MHPAEA Non-Enforcement Policy: Limited Impact?

Reinhart, Boerner, Van Deuren SC
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On May 15, 2025, the U.S. Departments of Labor, Treasury and Health and Human Services (collectively, the Departments) announced a temporary non-enforcement policy...

United StatesEmployment and HR
Stacie Kalmer
Stacie Kalmer
Gregory A Storm
Gregory A Storm
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On May 15, 2025, the U.S. Departments of Labor, Treasury and Health and Human Services (collectively, the Departments) announced a temporary non-enforcement policy related to the Mental Health Parity and Addiction Equity Act (MHPAEA) regulations issued in 2024 (the 2024 Regulations). We previously discussed the impact of the 2024 Regulations on health plan sponsors in this alert. The non-enforcement policy is in response to: (1) the ongoing litigation in ERIC v. HHS, challenging aspects of the 2024 Regulations; and (2) the Trump Administration directive to review all regulations for undue burden on small business or significant costs upon private parties that are not outweighed by public benefits.

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