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Vorys

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Vorys Benefits Brief: 2025 MHPAEA Report to Congress: Enforcement Activity Continues and the Need for Comparative Analyses Remains

The United States Departments of Labor, Health and Human Services, and the Treasury recently issued the 2025 MHPAEA Report to Congress, summarizing enforcement activity related to the Mental Health Parity and Addiction Equity Act (MHPAEA) for the period of August 1, 2023, through July 31, 2025. The Report reflects enforcement efforts by the Employee Benefits Security Administration (EBSA) and the Center for Medicare and Medicaid Services (CMS), with a focus on prior authorization, medical necessity review, utilization management and exclusions of key mental health and substance use disorder (MH/SUD) treatments.