On May 4, 2026, the IRS announced updated penalty amounts for 2027 under the Affordable Care Act’s (ACA) employer shared responsibility, or “pay-or-play,” rules. For the 2027 calendar year, the $2,000 penalty has been adjusted to $3,780, and the $3,000 penalty has increased to $5,670. This marks a rise from 2026 levels of $3,340 and … Continued
On May 29, 2026, the IRS issued Revenue Procedure 2026-24, which sets the inflation-adjusted limits for health savings accounts (HSAs) and high deductible health plans (HDHPs) for 2027. The updated limits address: Each of these limits differs depending on whether the coverage is for an individual or a family under an HDHP.
A New Era of Health and Welfare Fiduciary Litigation Health and welfare plan fiduciaries are entering a period of increased legal scrutiny. For many years, fiduciary litigation under the Employee Retirement Income Security Act of 1974 (ERISA) focused primarily on retirement plans, and particularly on allegations of excessive fees involving 401(k) plans. More recently, however, … Continued
DOL Extends Comment Period on Proposed PBM Fee Disclosure Rule The Department of Labor (DOL) has announced a short extension to the comment period for its proposed rule on pharmacy benefit manager (PBM) compensation transparency. The rule is intended to strengthen disclosure requirements for PBMs and related service providers working with self-insured group health plans subject to … Continued
If your company provides an employee benefit plan governed by the Employee Retirement Income Security Act (ERISA), you are likely obligated to file Form 5500. This annual report discloses key details about your organization’s benefit offerings, such as welfare benefit plans (including medical, dental, life, and disability coverage), retirement plans, fully insured plans, and self-funded … Continued
THE ANNUAL GAG CLAUSE ATTESTATION DUE DEC. 31, 2025 Under the rules adopted by Congress in the Consolidated Appropriations Act, 2021 (CAA), group health plans and health insurance issuers of both fully insured and self-funded plans must certify that their contracts with providers, networks, third-party administrators (TPAs), pharmacy benefit managers (PBMs), or other service providers … Continued
The U.S. Department of Health and Human Services (HHS) has issued a final rule that requires covered entities—including many health plans—to update their Notice of Privacy Practices (Privacy Notice). This change enhances privacy protections for highly sensitive Substance Use Disorder (SUD) treatment records. Why the Update is Necessary The HIPAA Privacy Rule already mandates that … Continued
Employers with insured health plans may have received a Medical Loss Ratio (MLR) rebate from their health insurance carrier this year. Rebates were required for plans not meeting the 2024 MLR standards and had to be issued by September 30, 2025, either as premium credits or lump-sum payments. If any part of the rebate qualifies … Continued
2026 PENALTIES FOR FAILURE TO FILE OR FURNISH ACA REPORTING FORMS The IRS has announced the 2026 penalties for failure by Applicable Large Employers (ALEs) to file or furnish Affordable Care Act (ACA) reporting Forms 1095-C and 1094-C for the 2025 tax year. Amounts can increase significantly depending on how late the filing is or … Continued
Open enrollment is a hectic and critical period for employers that often brings a risk of compliance errors. These mistakes can confuse employees and cause missed benefits, while also exposing employers to legal risks. This article highlights five common compliance pitfalls to avoid during open enrollment: Ineffective Communication of Benefit Changes – Benefit offerings often change … Continued
