Суд приостановил применение правил паритета психического здоровья

On May 9, 2025, the US Departments of Health and Human Services, Labor, and the Treasury filed a motion to pause litigation in the case of The ERISA Industry Committee vs. HHS et al. This decision comes as the government reevaluates the final regulations of the Mental Health Parity and Addiction Equity Act (MHPAEA).

The US District Court for the District of Columbia granted this stay on May 12. This lawsuit, initiated by the ERISA Industry Committee (ERIC), contests a rule introduced on September 23, 2024, which imposed new standards on group health plans concerning nonquantitative treatment limitations (NQTLs).

The Departments are reconsidering these 2024 regulations and may initiate a new rulemaking process to amend or revoke them. During this review period, the Departments are also preparing to implement a non-enforcement policy regarding parts of the 2024 regulations that affect plan years beginning on January 1, 2025, and January 1, 2026.

While the exact parameters of the non-enforcement policy remain undefined, ERIC argues that certain provisions in the 2024 Rule impose excessive burdens on plan sponsors. These include requirements for meaningful benefits, standards for material differences in access, and a need for fiduciary certification of comparative analyses.

This recent development aligns with a presidential directive issued on April 9, which instructed executive departments to identify regulations that may be unlawful or overly burdensome. The introduction of the 2024 Rule has created confusion among plan sponsors, making this pause a welcome relief for many struggling to comply.

It is important to note that, despite the suspension of enforcement for the 2024 Rule, plan sponsors must continue to ensure that NQTLs comply with existing parity requirements as stipulated in the MHPAEA. The obligation to document a comparable process for NQTLs remains intact, and the forthcoming non-enforcement policy does not alter this compliance requirement.

For further inquiries, interested parties should reach out to the authors of this blog or their respective contacts at Morgan Lewis.