--- title: MHPAEA 2024 Final Rule Enforcement Delay description: The MHPAEA 2024 Final Rule Enforcement Delay pauses new provisions while litigation and review proceed. Learn what this means for plans and issuers. --- [Skip to content](https://success.ctpa.com/blog/compliance-updates/mhpaea-2024-final-rule-enforcement-delay#main-content) [![Company Logo](https://success.ctpa.com/hubfs/Website%20Images/logo.svg)](https://ctpa.com/) - [Services](https://ctpa.com/services) - Who We Serve - [Members](https://ctpa.com/members) - [Employers](https://ctpa.com/employers) - [Providers](https://ctpa.com/providers) - [Brokers](https://ctpa.com/brokers) - [About Us](https://ctpa.com/about-us/) - Resources - [Member Resources](https://ctpa.com/resources/) - [Partner & Provider Resources](https://ctpa.com/partner-and-provider-resources/) - [Concierge Blog](https://success.ctpa.com/blog/) - [Compliance Updates](https://success.ctpa.com/compliance-updates/) - [Contact](https://ctpa.com/contact/) - [Secure Upload](https://us2.hostedftp.com/~secure@cbscas.com/) - Login - [Members Login >](https://cng.vbagateway.com/) - [Employers Login >](https://cng.vbagateway.com/) - [Providers Login >](https://cng.vbagateway.com/) # Concierge Blog March 18, 2026 ## Enforcement Delay of the 2024 Final Rule on Mental Health Parity and Addiction Equity Act Todd Archer, Concierge President The Departments of Health and Human Services, Labor, and Treasury (the “Departments”) have announced a delay in enforcement of certain provisions of the 2024 Mental Health Parity and Addiction Equity Act (MHPAEA) Final Rule. **How We Got Here** On September 9, 2024, the Departments issued the 2024 Final Rule titled *“Requirements Related to the Mental Health Parity and Addiction Equity Act.”* This rule updates and amends the 2013 final rule implementing the MHPAEA of 2008. Among other provisions, the 2024 Final Rule introduced new requirements for comparative analyses of nonquantitative treatment limitations (NQTLs), additional definitions, fiduciary certification requirements, and obligations to examine and provide data related to enforcement actions. The rule became effective on November 22, 2024, with applicability dates beginning January 1, 2025, for group health plans and January 1, 2026, for individual market plans. **Legal Challenge and Department Response** On January 17, 2025, the ERISA Industry Committee (ERIC) filed a lawsuit in the U.S. District Court for the District of Columbia challenging provisions of the 2024 Final Rule, alleging they are arbitrary and contrary to law under the Administrative Procedure Act. Following the litigation and Executive Order 14219, the Departments requested on May 12, 2025, that the final rule be put on hold. On May 15, 2025, the Departments announced that the rule would be temporarily non-enforced until 18 months after a final court ruling. During this interim period, the Departments are conducting a review process and may consider amendments, rescissions, or new rulemaking. **Temporary Nonenforcement Period** The Departments have confirmed: 1. They will not enforce the new provisions of the 2024 Final Rule (those not part of the 2013 rule) for violations until a final decision is reached in the ERIC litigation, plus 18 months thereafter. 2. This relief applies only to new provisions introduced in the 2024 Final Rule. Statutory obligations under MHPAEA as amended by the Consolidated Appropriations Act, 2021, remain in place. **Guidance for Plans and Issuers** During this period, health plans and issuers are advised to: - Continue relying on the 2013 final rule (published November 13, 2013). - Utilize the FAQs About Mental Health and Substance Use Disorder Parity Implementation and the Consolidated Appropriations Act, 2021 – Part 45. - Follow other subregulatory guidance previously issued by the Departments. The Departments have also noted they may issue updated FAQs or initiate new rulemaking as part of their ongoing reconsideration of the 2024 Final Rule. **Key Point for Employers and Issuers** While the 2024 Final Rule remains in effect, enforcement of its new provisions is on hold. Employers and issuers should maintain compliance with MHPAEA as amended and prepare for potential future regulatory updates. For more information, the Departments’ non-enforcement statement can be found [here](https://www.cms.gov/files/document/statement-regarding-enforcement-final-rule-requirements-related-mhpaea.pdf).  ## Subscribe for Updates #### [July 2026 IRS Announces 2027 HSA Contribution Limits](https://success.ctpa.com/blog/2027-hsa-contributions) #### [May 2026 Steady Hands in a Shifting Industry for Better Outcomes](https://success.ctpa.com/blog/steady-hands-in-a-shifting-industry) #### [April 2026 Why Human-Centered Self-Funding Works](https://success.ctpa.com/blog/why-human-centered-self-funding-work) #### [March 2026 Data That Moves the Needle](https://success.ctpa.com/blog/data-that-moves-the-needle) #### [March 2026 Trump’s “Great Healthcare Plan” Framework](https://success.ctpa.com/blog/compliance-updates/trumps-great-healthcare-plan) #### [March 2026 How the Supreme Court Ruling on Section 1557 Impacts the Catholic Benefits Association](https://success.ctpa.com/blog/compliance-updates/supreme-court-ruling-section-1557-catholic-benefits-association) #### [March 2026 What Employers Need to Know: The One Big Beautiful Bill Enhances HSAs and FSAs](https://success.ctpa.com/blog/compliance-updates/unwritten-rules-in-healthcare-benefits-concierge-tpa) #### [March 2026 Primer on the Federal IDR Process for Surprise Medical Billing](https://success.ctpa.com/blog/compliance-updates/primer-on-the-federal-idr-process-for-surprise-medical-billing-december-2024) [![Company Logo](https://success.ctpa.com/hubfs/Website%20Images/logo-footer.svg)](https://ctpa.com/) **OKC Office** 13900 N Portland Ave., Suite 101 Oklahoma City, OK 73134-4017 **Bartlesville Office** 300 SE Frank Phillips Blvd Suite 200, Bartlesville, OK 74003 **Claims** P.O. 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