The Tax Extenders and AMT Relief Act (“Extenders Act”) makes permanent provisions of the Mental Health Parity Act of 1996 (“MHPA”), which provides that group health plans offering mental health benefits cannot impose aggregate lifetime or annual dollar limits on mental health benefits that are not imposed on substantially all medical and surgical benefits. For plan years beginning after October 3, 2009, the Extenders Act also requires that group health plans impose no more restrictive “financial requirements” or “treatment limitations” on mental health benefits than they do on substantially all medical and surgical benefits. For these purposes, “financial requirements” include deductibles, copayments, coinsurance, and out-of-pocket expenses, and “treatment limitations” include limits on the frequency of treatment, number of visits, and days of coverage. The Extenders Act also limits the exemptions originally provided for under the MHPA. Regulatory guidance is expected. Any delays in issuing regulations, however, will not change the effective date of the new requirements. In light of these significant changes to the mental health parity rules, you should begin reviewing your plan’s benefits structure to ensure it will be compliant with the new provisions when they go into effect.