Mental Health Parity: DOL’s New Enforcement Priorities and What Plan Sponsors Need to Know

Thompson Hine LLP

On September 8, the Department of Labor issued new guidance clarifying its enforcement approach under the Mental Health Parity and Addiction Equity Act (MHPAEA). Although the Departments are not currently enforcing certain portions of the 2024 MHPAEA final rule, the statutory requirements governing nonquantitative treatment limitations (NQTLs), including the requirement to prepare comparative analyses, remain in effect. The DOL has now identified three areas as particular enforcement priorities: separate treatment limitations and exclusions; medical necessity standards and review processes; and network adequacy, including provider admission standards and reimbursement methodologies. Join Thompson Hine lawyers Beth Mandel and Kristin Koenecke for a practical discussion of what DOL’s revised enforcement approach means for group health plan sponsors and administrators. We will review the new guidance, highlight the compliance “red flags” DOL says it will look for, and discuss practical steps employers can take to evaluate their plans, work with carriers and third-party administrators, and prepare for potential DOL scrutiny.

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