Spencer Fane attorneys Natalie Miller and Laura Fischer authored an article, New Announcement on MHPAEA Rules May Mislead Employers, recently published by BenefitsPRO.
The piece originated as a June 2025 post on the firm’s Benefits in Brief blog. In it, Natalie and Laura discuss Mental Health Parity and Addiction Equity Act (MHPAEA) documentation requirements that still apply to group health plan sponsors despite a May announcement from the U.S. Departments of Labor, Health and Human Services, and Treasury that may lead them to think otherwise.
“Regulators expect plans to be in compliance with the MHPAEA requirements added by the CAA, including the comparative analysis requirement,” the team says. “It is important to note that the 2024 final regulations have not been modified or rescinded – instead, regulators have simply announced that they will not enforce those regulatory requirements at this time. Plan sponsors should continue to monitor this issue and pay attention to any additional guidance that may be issued.”
At Spencer Fane, Natalie and Laura provide valuable legal services as members of the Employee Benefits team. They proactively advise clients on matters including ERISA, the tax code, HIPAA, COBRA, and various health care reform mandates. With their counsel, plan providers, administrators, and employers can more adeptly navigate the complex and ever-changing regulations regarding the administration and distribution of employee benefits.
Read the team’s full article here. Please note, a subscription may be required.