According to the 2025 SHRM Employee Benefits Survey, 90% of employers now offer mental health coverage, up from 84 percent in 2019. And yet many employers find those benefits aren’t being used even as exit interviews report issues they could help, such as burnout and mental exhaustion.
At Business Benefits Group (BBG), we offer health insurance plans that do more than include mental health coverage and counseling as a line item that risks being forgotten in the fine print. Rather, we work with our clients to build mentally resilient teams by helping them communicate the benefit to employees and making their benefits easy to use.
Why EAP Use Rarely Matches Enrollment Numbers
Over a quarter of employees, 26%, say they don’t know whether their employer offers mental health benefits such as an employee assistance program (EAP), flexible scheduling, or paid time off tied to mental health. And only about half know how to access the benefits they already have, according to a 2025 workplace mental health poll reported by SHRM.
SHRM also reports that 31% of workers say their job makes them feel stressed “always or often.” That is the primary population an EAP is meant to serve, and yet fewer than 10 percent of eligible employees in the U.S. take advantage of programs they and their employers are already paying for.
An employer can’t control their employees’ actions or force them to use a benefit. But those numbers suggest that employers can take proactive steps to increase participation in their programs.
An experienced benefits consultant will start by auditing where the disconnect between availability, awareness, and use actually occurs. That disconnect may arise in the communication cadence or manager training, or it could be in the employee’s fear of being stigmatized for seeking help with their mental health.
The consultant will then build a plan to address the real issues. For example, by increasing the communication cadence through emails, or reassuring employees of the confidential nature of any medical help they receive.
The Real Cost of Treating Mental Health as an Add-On
The Kaiser Family Foundation’s 2025 Employer Health Benefits Survey found that firms are far less confident their largest health plan provides timely access to mental health services (70%) than they are about access to primary care (92%) or specialty care (89%).
That lack of confidence in how their plans support their employees’ mental health may also show up in problems with the network. An employee who tries to book an appointment but can’t find an in-network provider may simply give up before they get care.
A structural approach to planning mental health benefits connects four components:
- The network of behavioral health providers has to be large enough to handle the actual caseload that may come from the employee base. That network can’t only be based on a count of who is in the directory.
- An EAP needs a referral threshold low enough that managers actually use it for everyday stress and workload concerns, not only crisis situations. This means that a concerning behavior needs to trigger a review or discussion before the employee reaches their tipping point and leaves the company.
- Stress management resources belong in the working wellness budget rather than treated as a perk that gets cut first when costs tighten.
- Manager training has to teach supervisors how to recognize burnout signals and make a warm handoff to the EAP, rather than trying to manage a mental health issue themselves or treat it as something to be stigmatized.
Each one of these components reinforces the others. A well-designed EAP with no manager training goes unused. Manager training paired with a thin behavioral health network sends employees into a system that can’t see them for weeks or months. And a resource that is periodically cut to improve the bottom line isn’t one that employees feel they can count on.
The Parity Compliance Layer Most HR Directors Have Not Verified
HR directors don’t need to become compliance attorneys to manage this well, but they do need to know that behavioral health coverage will carry specific legal obligations under the Mental Health Parity and Addiction Equity Act (MHPAEA).
The law stipulates that financial requirements and treatment limitations on mental health and substance use disorder benefits be no more restrictive than those applied to medical and surgical benefits. In other words, mental health benefits need to be as easy and affordable to access as medical or surgical treatments.
To support this, the Department of Labor, HHS, and Treasury issued a final rule in September 2024 that added new documentation requirements for comparative analyses of non-quantitative treatment limitations, with most provisions applying to plan years beginning on or after January 1, 2025.
Then, in May 2025, the departments announced they would not enforce that 2024 final rule due to litigation over its validity. While those court cases proceed, plus an additional 18 months after a final court decision, new portions of the2024 final rule are effectively on hold.
However, the underlying 1996, 2008, and 2021 parity statutes remain in force. This means a plan’s network adequacy, prior authorization rules, and behavioral health reimbursement rates still need to hold up against medical and surgical benefits. Employers and plans are not relieved of the NQTL requirements, even while the newest comparative analysis paperwork is on hold.
This is educational context, not legal advice, and any plan-specific parity question should go to ERISA (Employee Retirement Income Security Act) counsel. What a benefits consultant can do, and what many brokers skip, is benchmark a plan’s behavioral health network and cost-sharing structure against its medical plan.
How BBG Measures Whether a Program Is Actually Working
BBG follows a six-step process for advising and supporting businesses with employee benefits:
- Planning and Education
- Assess Performance and Perception
- Strategic Design
- A Plan of Action
- Communication and Delivery
- Support and Optimization
In the second stage of this process, Assess Performance and Perception, we gather information about use and claims patterns, as well as employee opinions and survey results. We compare that information to industry benchmarks from SHRM, the Kaiser Family Foundation, and others, and we use it to begin the design of a plan built for you.
This strategic design phase positions mental health support as an important aspect of the value of the total benefits package for employees. It isn’t only about reducing perceptions of being overworked and working to lower turnover rates. Competent design is about improving the employee’s total quality of life through mental health support.
This is where benefits program branding comes in. A midsize employer that rebuilds its behavioral health communication around real numbers, what its program covers, how fast an employee can get a first appointment, and what it costs turns a benefit line item into a recruitment talking point.
And the sixth stage of our process at BBG, Support and Optimization, means revisiting the program and updating it against new survey benchmarks and internal use data as needed.
What This Means for Your Next Renewal Conversation
The pause the Department of Labor has taken while parts of MHPAEA are being litigated does not remove an employer’s underlying obligations. Mental health programs still need to meet earlier standards that covered program adequacy and reimbursement rates, and after the court’s ruling (and an additional 18 months), employers will have a limited window to adjust their programs to the new standards.
Low EAP use is often a problem with design and communication, not a sign employees don’t want or need the support. At BBG, we work with HR directors to review where a mental health benefit is underperforming, benchmark it against current data from industry leaders, and rebuild the communication and manager training layer as part of a longer-term benefits strategy rather than a one-time fix at renewal.
To schedule a review of your organization’s EAP and behavioral health coverage, contact Business Benefits Group, or learn more about how our six-step process applies to mental health and wellness programs.