Michigan Law

The 2025 Parity Non-Enforcement Statement

The statute itself still applies.

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The details

What the statement said

The 2024 rule

Issued September 9, 2024, it amended the 2013 rule and added requirements for non-quantitative limit comparative analyses.

The litigation

The ERISA Industry Committee sued on January 17, 2025.

Enforcement relief

The Departments will not enforce the new portions of the 2024 rule for failures occurring before a final decision in the litigation, plus 18 months.

What continues

The statute’s obligations, as amended by the Consolidated Appropriations Act, 2021, continue. Plans may refer to the 2013 rule and subregulatory guidance.

Back to the ABA guide.

Questions We Get

The 2025 Parity Non-Enforcement Statement: short answers

Is parity still the law?

Yes. The statute continues to have effect.

Has this changed since May 2025?

Check the Departments’ site. The status could have changed.

What should employers do?

Keep comparative analyses current and ask counsel.

The 2025 Parity Non-Enforcement Statement: not legal advice. Send us your renewal.

Sources

Where these details come from

The laws and rules named on this page link to the official text. This is general information, not legal advice, and rules change, so check the current text.

U.S. Departments of Labor, HHS and Treasury: 2025 parity enforcement statement

CMS: Mental Health Parity and Addiction Equity Act

Let’s Get to Work

Send us your renewal.

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What to send

The renewal letter
Your current plan summary
Contribution split by tier
Enrolled counts by tier

Four documents — two more if your group is 50 or more. Nothing else; every extra one is a reason to postpone.

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