H.R. 3758 — Workers’ Disability Benefits Parity Act of 2025

This section establishes parity requirements for disability benefits (i.e., payments for loss of earning capacity due to injury or sickness) in employee welfare benefit plans under ERISA (29 U.S.C. 1021 et seq.). Such plans (1) may not impose limitations, exclusions, or restrictions on disabilities from mental health conditions or substance use disorders that are more restrictive than those for physical conditions and (2) must treat any physical conditions caused by such mental health or substance use disorder disabilities as part of the disability. It authorizes the Secretary of Labor to assess civil monetary penalties against violators (excluding plans) in the amount specified under ERISA §502(c)(10)(B) for each day of noncompliance per affected participant or beneficiary.

This section establishes definitions for terms used in the title. It incorporates definitions from ERISA section 3 (29 U.S.C. 1002)—with modifications including the exclusion of federal government plans from "governmental employee benefit plan" (defined by reference to ERISA's "governmental plan")—for (1) administrator, (2) employer, (3) governmental employee benefit plan, (4) issuer (i.e., state-licensed insurers subject to state insurance regulation, excluding employee benefit plans), (5) Secretary (of Labor), and (6) State (i.e., the 50 states, District of Columbia, Puerto Rico, Virgin Islands, Guam, American Samoa, and Northern Mariana Islands); and (7) defines disability benefit, disability benefit plan, mental health condition, and substance use disorder by reference to ERISA section 901.

This section requires governmental employee benefit plans and issuers providing disability benefits to apply parity between mental health conditions or substance use disorders and physical health conditions by (1) prohibiting limitations, exclusions, or restrictions on the former that are more restrictive than those on the latter; and (2) treating any physical health condition caused by a mental health condition or substance use disorder as part of that disability.

This section establishes enforcement mechanisms under this title for disability benefits provided by governmental employee benefit plans and insurance issuers. (a) It authorizes each state to enforce this title's requirements against such issuers operating in the state and directs the Secretary to enforce them if a state fails to substantially do so. (b) It authorizes the Secretary to assess civil monetary penalties, in the amount specified in ERISA section 502(c)(10)(B) (29 U.S.C. 1132(c)(10)(B)) for each day of the noncompliance period with respect to each affected participant or beneficiary, against responsible entities—including issuers, multiemployer plan administrators, or single-employer sponsors—that violate this title; it also makes available to the Secretary all powers, remedies, and procedures under ERISA part 5 (29 U.S.C. 1101 et seq.). (c) It authorizes any aggrieved individual to bring an action for appropriate equitable relief in state or federal court.

This section preserves the applicability of state laws that establish, implement, or continue requirements or prohibitions with respect to disability benefits, except to the extent such state laws prevent the application of this title.

This section directs the Secretary of Labor, not later than 18 months after enactment of this Act, to (1) conduct a study on the cost to ERISA plan sponsors (i.e., employers sponsoring employee benefit plans) of providing disability benefits for participants and beneficiaries disabled by behavioral health conditions, including an actuarial cost analysis; and (2) conduct outreach to plan sponsors on how duration limits affect access to benefits for participants and beneficiaries with mental health or substance use disorder conditions.

This section authorizes the Secretary of Labor to issue regulations, sub-regulatory guidance, and interim final rules as necessary to implement this Act.

This section establishes the effective date for amendments made by this Act as applicable to plan years beginning after 18 months after the date of enactment. For plans maintained under one or more collective bargaining agreements ratified before enactment, the amendments apply to plan years beginning after the later of (1) the termination of the last such agreement (disregarding post-enactment extensions) or (2) 18 months after enactment; plan amendments made solely to conform to the Act's requirements do not constitute a termination of such agreements.