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State Level Health Coverage Reporting Deadlines

  • On November 18, 2025
The Affordable Care Act (ACA) created several federal reporting requirements for employers and health plans, which (among other things) provide the government with information to administer ACA mandates, such as the large employer shared responsibility penalty and the individual mandate. The ACA’s individual mandate became effective in 2014, and it requires individuals to obtain minimum […]
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IRS Finalizes 2025 ACA Reporting Instructions

  • On November 11, 2025
On November 5, 2025, the Internal Revenue Service (IRS) released the final instructions for Affordable Care Act (ACA) reporting requirements under Internal Revenue Code Sections 6055 and 6056.
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Gag Clause Compliance for Group Health Plans Overview

  • On November 4, 2025
Federal regulations bar group health plans and health insurers from entering into agreements that restrict access to specific data regarding provider pricing or service quality. These contractual limitations—known as “gag clauses”—can prevent plans from sharing or obtaining vital cost and care information. To ensure compliance, plans and insurers must file an annual attestation with the […]
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IRS Releases Health FSA Limits for 2026

  • On October 14, 2025
On October 9, 2025, the IRS released Revenue Procedure 2025-32 (Rev. Proc. 25-32), which includes the 2026 inflation-adjusted limit on employee salary reduction contributions to health flexible spending accounts (FSAs). For plan years beginning in 2026, the adjusted dollar limit on employees’ pre-tax contributions to health FSAs increases to $3,400. This is a $100 increase from the 2025 […]
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Government Shutdown Halts Many EBSA Operations, Delays Likely for Employers

  • On October 7, 2025
As of Wednesday, October 1, the federal government has entered a shutdown that will remain in effect until further notice. This has significantly impacted the Employee Benefits Security Administration (EBSA), a division of the U.S. Department of Labor (DOL) responsible for enforcing regulations related to health and retirement benefits. According to the DOL, roughly 504 […]
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Still Waiting for the IRS to Issue Final Versions of Forms 1094/1095-B/C

  • On October 1, 2025
In June 2025, the Internal Revenue Service (IRS) released draft 2025 forms for Affordable Care Act (ACA) reporting under Internal Revenue Code Sections 6055 and 6056. Thereafter, on September 17, 2025, draft instructions for the C series forms were released; however, the IRS has not yet released draft instructions for the B series forms. No […]
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ACA Pay-or-Play Rules: Key Changes for 2026

  • On September 17, 2025
The Affordable Care Act (ACA) requires applicable large employers (ALEs) to provide affordable, minimum-value (MV) health coverage to full-time employees (FTEs). Employers that fail to do so may face penalties if at least one FTE qualifies for a premium tax credit (PTC) to buy coverage on the Exchange. This requirement—commonly called the “employer shared responsibility” […]
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Year-End Disclosure Deadlines for Health Plans

  • On September 9, 2025
As the end of the calendar year approaches, employers that sponsor group health plans must ensure timely compliance with several federal reporting and disclosure requirements. These obligations, mandated under various federal laws, including the Employee Retirement Income Security Act (ERISA), the Affordable Care Act (ACA), and the Consolidated Appropriations Act(CAA), must be fulfilled promptly to […]
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ACA Employer Shared Responsibility: Key Updates for 2026

  • On September 3, 2025
The Affordable Care Act (ACA) requires applicable large employers (ALEs) to provide full-time employees (FTEs) with health coverage that is both affordable and of minimum value (MV). Employers that fail to meet these standards may face penalties under the “employer shared responsibility” (commonly called the “pay-or-play” rules). An ALE only becomes liable for penalties if one or more […]
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Medicare Creditable Coverage Determinations for 2026

  • On August 27, 2025
The Centers for Medicare and Medicaid Services (CMS) issued Final Part D Redesign Program Instructions for calendar year 2026. The instructions contain a detailed description of and guidance related to changes to the Medicare Part D benefit made by the Inflation Reduction Act of 2022 (IRA) that are newly in place for calendar year 2026. These changes […]
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