Matthew A. Criswell

The Mental Health Parity and Addiction Equity Act (MHPAEA) requires group health plans to provide mental health and substance use disorder (MH/SUD) benefits equal to medical/surgical benefits. In September 2024, federal agencies issued the 2024 MHPAEA Final Rule, introducing new compliance requirements with effective dates beginning January 1, 2025.  

Employer plan sponsors that impose tobacco use surcharges on participants enrolled in group health plans should take immediate notice of recent litigation and enforcement trends targeting wellness program compliance under the Affordable Care Act (ACA), HIPAA, ERISA, and related regulations.  

Making several changes, the IRS has released the 2023 cost-of-living adjustments applicable to the dollar limits and thresholds for retirement plans and health and welfare benefit plans. Plan sponsors should update their systems and formulas to include the limits that have been adjusted.  

The Securities and Exchange Commission (“SEC”) recently proposed rule changes applicable to public companies to enhance and standardize disclosures concerning cybersecurity risk management, strategy, governance, and cybersecurity incident reporting. The proposed rules would amend rules regarding current and periodic reporting requirements. These proposed amendments are intended to better inform investors about a registrant’s risk management, strategy, and governance and to provide timely notification of material cybersecurity incidents.