Compliance and deadlines

MHPAEA fiduciary certification effective January 1, 2025

Originally posted by

New Fiduciary Certification Requirements Effective January 1, 2025

BLUF: Plan sponsors must choose a vendor to perform a Comparative Analysis and document their selection process.

The MHPAEA Final Rule introduces affirmative obligations for group health plans under ERISA: starting January 1, 2025, plan sponsors must comply with Fiduciary Certification requirements to ensure equitable access to mental health and substance use disorder benefits.

Plan Sponsors must:

1. Select a vendor to perform a Comparative Analysis.

2. Document why they chose that vendor over others.

3. Review the Comparative Analysis and discuss defect remediation with other vendors (networks/UM/etc.).

4. Engage in continuous improvement to continue refining the program.

MHPAEA compliance is a top DOL enforcement priority and Plan Sponsors must take action to comply. There is no “accidental” compliance with MHPAEA.

Sources

  • Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA)

Originally posted on LinkedIn, where the discussion and source links live in the comments.

About the author

Chris Vanderwolk is Director of Compliance and Innovation at OneDigital | Kistler Tiffany Benefits General Agency, where he helps brokers and employers navigate the regulatory complexity of employee benefits. An ERISA attorney with more than 19 years in the benefits industry, he specializes in translating what the law actually requires into language people can use.

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