On June 11, 2025, Assistant Attorney General Brett Shumate issued a memorandum to all U.S. Department of Justice Civil Division employees outlining enforcement priorities under directives from President Trump and Attorney General Bondi. The Memorandum signals a shift in federal enforcement focus to issues such as discrimination, gender transition care, and immigration, and identifies the False Claims Act as a tool to achieve certain of the Administration’s goals.  

While recent regulatory developments—including the Departments’ nonenforcement policy, proposed legislation, and new transparency rules—offer employers and plan fiduciaries greater flexibility and potential relief, they also underscore the need for continued vigilance. From ensuring compliance with longstanding MHPAEA obligations to evaluating benefit design changes, managing PBM relationships, and addressing nondiscrimination concerns in self-funded plans, stakeholders must stay proactive and informed to navigate the evolving health and welfare benefits landscape effectively.While recent regulatory developments—including the Departments’ nonenforcement policy, proposed legislation, and new transparency rules—offer employers and plan fiduciaries greater flexibility and potential relief, they also underscore the need for continued vigilance. From ensuring compliance with longstanding MHPAEA obligations to evaluating benefit design changes, managing PBM relationships, and addressing nondiscrimination concerns in self-funded plans, stakeholders must stay proactive and informed to navigate the evolving health and welfare benefits landscape effectively.