Just a Minute! on DOL's Recent Mental Health Parity Guidance

September 25, 2026

As we reported in the September 15 Benefits Byte, the U.S. Department of Labor issued Field Assistance Bulletin 2026-03 on September 8, providing additional clarity on the DOL’s approach to enforcing the non-quantitative treatment limitation (NQTL) requirements of the Mental Health Parity and Addiction Equity Act (MHPAEA), along with an enforcement guidance tool intended to help plans and issuers.

Employer compliance with MHPAEA’s NQTL rules has been a challenge and enforcement has been in flux over the past several years. In DESTINATION 2030, our long-term public policy strategic plan, we called for clearer, fairer mental health parity guidance.

In this episode of Just a Minute!, Council President Katy Johnson calls on employers to share their experiences with mental health parity requirements as we await the issuance of new proposed regulations, possibly before the end of 2026.