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.

Missouri, Alaska and Nebraska joined the growing number of states requiring certain employers to provide paid leave. Beginning in 2025, these laws will impact most employees in these states, with few exceptions. Massachusetts, Connecticut and New York represent states amending their leave policies.

October brought the second of two Centers for Medicare & Medicaid Services (CMS) Medicare Part D annual disclosures, in the form of Creditable Coverage Letters. The IRS released the 2025 cost-of-living adjustment information affecting employee benefit plans. We were reminded that while there are no federal requirements for time off to vote, many states mandate it. Employers sponsoring an individual coverage HRA (ICHRA) should have provided their annual notice to plan participants. An FAQ was released providing guidance on the requirements of the Women’s Health and Cancer Rights Act. As open enrollment begins for many employers, remember important tips to remain compliant.

September brought the due date for the Summary Annual Report, which summarizes the Form 5500 contents. Employers prepared to send out the required Medicare Part D Creditable Coverage letters to eligible participants and enrolled beneficiaries. The Departments released final rules on the MHPAEA NQTL analysis. California insurers are required to cover in-vitro fertilization for large groups. The IRS released the 2025 ACA affordability percentage, and the DOL updated cybersecurity guidance for health and welfare plans.

In August, the FTC ban on non-compete agreements was struck down by a court stating that the FTC did not have the power to implement the ban and that its application was too broad. The FDA approved new and updated COVID-19 vaccines for adults and children as part of the preventive care mandate for group health plans. The Biden administration released its Unified Agenda, containing regulations impacting group health plans, and announced their anticipated release dates. New Hampshire announced an improved prior authorization process. The Johnson & Johnson breach of fiduciary trust lawsuit saw some movement and a similar suit was brought against Wells Faro and its fiduciaries.

July was a busy month for sponsors of group health plans. The final DOL rule on overtime exemption requirements went into effect July 1. IRS Form 5500, due on July 31 for calendar year plans, applies to most public and private sector businesses providing plans to 100 or more participants. Also due by July 31 was the annual PCORI fee, submitted via Form 720 by employers sponsoring self-funded medical plans or applicable HRAs. CMS announced updated parameters for Medicare Part D prescription coverage that will impact employers who need at provide documentation of creditable coverage to employees by October 31 and to disclose to CMS its creditable coverage within 60 days of the start of the plan year.

June saw the ACA Preventive Care Mandate upheld, with an exception that could open it up for future challenges. There was more movement on reproduction rights and privacy, where healthcare providers are barred from disclosing sensitive information to law enforcement without patient consent. Enforcement began on the Pregnant Workers Fairness Act (PWFA), which mandates that employers provide reasonable accommodations to employees affected by pregnancy, childbirth, or related medical conditions. The Supreme Court issued a unanimous decision in upholding the FDA's current protocol for mifepristone, commonly known as the abortion pill. Employers prepared to file IRS Form 5500.

In May, employers sponsoring self-funded medical plans or an applicable HRA began preparing to submit the PCORI fee, due July 31. The IRS released inflation-adjusted amounts for 2025 HSAs, EBHRAs, and HDHPs. The ACA Section 1557 nondiscrimination regulations were finalized, broadening the definition of impacted entities. The Medical Debt Cancellation Act was introduced, aiming to eliminate medical debt in certain circumstances. Connecticut Paid Sick Leave was expanded.