September saw employers preparing for the distribution of potential MLR rebates, while New York City readies for an expansion to its Earned Safe and Sick Leave Act. Applicable employers prepare to comply with the Gag Clause Attestation due in December. Sponsors of dependent care FSAs considered how the higher limit in 2026 may impact the ability to pass non-discrimination testing. California group health plans lock in the federal preventive care and vaccine recommendations that were in effect as of January 1, 2025.

In August, North Carolina’s Governor signed the SCRIPT Act into law, regulating PBM transparency and strengthening consumer and pharmacy protections. Texas extended the time for new parents to enroll their newborns in coverage from 31 to 60 days from the date of birth. Employers prepare to send out Medicare Part D Creditable Coverage letters to applicable individuals. Illinois expands dependent coverage rules to eligible dependent parents and stepparents of insured employees.

July brought the Final Rules on the One Big Beautiful Bill Act (OBBBA), enacted on July 4, 2025. The 2026 ACA affordability threshold has been released, affecting employer and employee contributions to group health plans.

June saw the Supreme Court uphold and affirm the authority of the Department of Health and Human Services (HHS) to appoint and oversee members of the body that evaluates and recommends preventive treatments as part of the Affordable Care Act. Employers can review their options should they receive a medical loss ratio rebate from their carrier. The HHS updated 2026 cost-sharing limits, and the Supreme Court upheld Tennessee’s ban on gender-affirming care for minors.

In May, applicable large employers were focused on RxDC reporting, due in June, and the PCORI filing, due in July. The U.S. Departments of Labor, Health and Human Services, and the Treasury jointly announced a pause in enforcement of the 2024 Final Rule implementing the Mental Health Parity and Addiction Equity Act (MHPAEA), and a federal court blocked the EEOC’s mandate of accommodations for elective abortions. The “One Big Beautiful Bill Act” was passed by the U.S. House of Representatives and will be considered by the Senate. The IRS Released 2026 cost-of-living adjustments for HSAs, HDHPs, and EBHRAs.

The Maryland Paid Family and Medical Leave Insurance program is delayed, and the definition of “Employer” under Maryland’s Parental Leave Act gains clarification. The DOL released an updated version of the CHIP Model Notice and covered employers under the San Francisco Health Care Security Ordinance (HCSO) need to submit the 2024 Employer Annual Reporting Form. Affected filers can use IRS Form 8928 to Report Certain Excise Tax.

In March, employers submitted their electronic filings to the Internal Revenue Service for the Affordable Care Act reporting requirement. Medicare Part D disclosure to CMS, certain reporting on HIPAA breaches, and MEWA Form M-1 were due in March.

The federal government in 2025 has is experiencing significant internal restructuring, workforce reductions, and communication restrictions across various departments. The results from the Departments of Labor and Health and Human Services investigations into Mental Health Parity and Addiction Equity Act (MHPAEA) enforcement have been shared. The IRS has eased regulations surrounding ACA reporting, Centers for Medicare & Medicaid Services (CMS) online disclosures come due, and President Trump signs an executive order on price transparency.

January brought guidance on the management of taxes on state paid family and medical leave, and an update on the much-watched Johnson & Johnson fiduciary lawsuit. The Department of Health and Human Services provided the 2025 Federal Poverty Levels and FAQs clarify gag clause prohibitions and No Surprises Act compliance relating to downstream contracts. The IRS released Publication 969, providing a reference on compliance for tax-favored accounts. Employers are reminded to file Forms 1094-C and 1095-C and submit the Medicare Part D disclosure. The Department of Labor released inflation-adjusted civil penalties for 2025.

December brought two bills easing employer ACA reporting requirements. President Biden stepped away from proposed changes to the birth control opt-out for moral objections. The pre-deductible status of telehealth in HSA plans expired, and the CAA 2024 Gag Clause Attestation submission took effect.