Top Health Plan Compliance Issues for 2025

Employers should be aware of the top compliance issues that may impact their health plan coverage for 2025. Some of these compliance issues are established requirements for employers, such as the new simplified reporting under the Affordable Care Act (ACA).

Other compliance issues are anticipated developments employers should monitor, such as additional health care transparency requirements.

New Executive Order Aims to Reduce Drug Costs by Aligning with Global Prices

On May 12, 2025, President Donald Trump issued an executive order (EO) that aims to bring the prices Americans pay for prescription drugs in line with those paid by similar nations.

According to a White House fact sheet, the prices Americans pay for brand-name drugs are more than three times the price other nations pay.

HSA/HDHP Limits Will Increase for 2026

On May 1, 2025, the IRS released Revenue Procedure 2025-19 to provide the inflation-adjusted limits for health savings accounts (HSAs) and high deductible health plans (HDHPs) for 2026.

Jan. 1, 2026: The new contribution limits for HSAs become effective.
2026 Plan Years: The HDHP cost-sharing limits for 2026 apply for plan years beginning on or
after Jan. 1, 2026.

Keeping Up With Compliance Quarterly

Keeping up with compliance developments can be difficult and time-consuming. This quarterly update highlights recent legal developments to help your organization stay on top of new requirements and minimize compliance risks. Inside: The Michigan Legislature has passed bills altering increases to minimum wage and paid sick time that were ordered by the Michigan Supreme Court last year. The bills were signed by Gov. Gretchen Whitmer on Feb. 21, 2025, and took effect immediately.

Employee Compensation and Benefits During Layoffs and Furloughs

This Compliance Overview summarizes the employee benefits and compensation issues employers may encounter when terminating or suspending employment. However, this Compliance Overview only addresses federal requirements. Therefore, employers may also consider reviewing state and local laws for additional legal requirements.

DOL Updates Model Employer CHIP Notice

The U.S. Department of Labor (DOL), through its Employee Benefits Security Administration (EBSA), has released a new model Employer CHIP Notice with information current as of March 17, 2025.

Employers that maintain group health plans in states with premium assistance subsidies must provide their employees with an annual notice. The DOL has a model notice for employers to use. Employers could also choose to prepare their own notices or modify the model notice.

IRA Changes to Medicare Part D May Impact Employer Plans

The Inflation Reduction Act of 2022 (IRA) includes several cost-reduction provisions to Medicare Part D plans that are designed to help beneficiaries but may also impact employer-sponsored health plans. Lower Medicare costs could mean higher costs for employers that provide prescription drug coverage as pharmacies and providers seek to make up for lost revenue by increasing costs in the private sector. The changes may also affect the creditable coverage status of employer-sponsored prescription drug coverage.

Employers Should Start Preparing for 2025 RxDC Reporting

Group health plans and health insurance issuers must annually submit detailed information on prescription drug and health care spending to the Centers for Medicare & Medicaid Services (CMS). This reporting is referred to as the “prescription drug data collection” (or “RxDC report”). The next RxDC report is due by Sunday, June 1, 2025, covering data for 2024.

Employers Must File ACA Returns Electronically by March 31, 2025

Employers that have not requested an extension or an electronic filing waiver, and that are subject to the ACA reporting rules should be exploring options for filing ACA reporting returns electronically to ensure filing is completed by the March 31, 2025, deadline. Electronic filing is done using the ACA Information Returns (AIR) Program. This ACA Compliance Bulletin provides detailed information on the electronic reporting process.

Executive Order Directs Federal Agencies to Improve Health Care Price Transparency

On Feb. 25, 2025, President Donald Trump issued an executive order (EO) titled Making America Healthy Again by Empowering Patients With Clear, Accurate, and Actionable Healthcare Pricing Information. By making more meaningful price information available to patients, this EO aims to promote a more competitive, innovative, affordable and higher-quality health care system.

5 Employee Benefits Trends Shaping 2025

Employee benefits are transforming, and employers can get ahead of these changes as they strive to attract and retain top talent. The modern workforce is multigenerational, with evolving expectations around work-life balance, mental health and personalized benefits. In this dynamic environment, understanding and implementing the latest trends in employee benefits can set an organization apart as an employer of choice. This article explores five key trends that will shape employee benefits in 2025.

DOL Releases Audit Results of ERISA Enforcement During 2024

The U.S. Department of Labor (DOL) has released the results of its Employee Benefits Security Administration’s (EBSA) enforcement actions during fiscal year (FY) 2024. This Legal Update explains further.

By enforcing the Employee Retirement Income Security Act (ERISA), the EBSA oversees approximately 2.6 million health plans, 801,00 private pension plans, and 514,000 other welfare benefit plans.

Medicare Part D Disclosures due by March 1, 2025

This is an annual reminder for employers whose health plans include prescription drug coverage to disclose to the Centers for Medicare & Medicaid Services (CMS) whether that coverage is creditable.

Employers must complete an online disclosure with CMS within 60 days after the beginning of the plan year, or March 1, 2025, for calendar year plans. This Legal Update explains further.

ERISA Fiduciary Breach Claims Dismissed in J&J Lawsuit

On Jan. 24, 2025, a U.S. District Court for the District of New Jersey dismissed two claims in a class-action lawsuit filed against Johnson & Johnson (J&J), which alleged that the company breached its fiduciary duties under ERISA by mismanaging its prescription drug benefits plan.

While the J&J ruling can be viewed favorably for employers in their roles as plan sponsors, the outcome of fiduciary litigation that was filed after the J&J case remains to be seen.

IRS Issues Revenue Ruling on State PFML Contributions

The IRS has issued Revenue Ruling 2025-4, providing guidance on the federal tax treatment of contributions and benefits under state-paid family and medical leave programs.

This Compliance Bulletin provides more information about the requirements discussed in the ruling.

Mental Health Parity Continues to Be a Top Enforcement Priority

The Employee Benefits Security Administration (EBSA) recently released its annual enforcement report on the Mental Health Parity and Addiction Equity Act (MHPAEA). According to EBSA, MHPAEA compliance remains one of its top enforcement priorities. This Compliance Bulletin discusses EBSA’s enforcement of MHPAEA, including factors that may impact enforcement efforts in the future.

Common Health Plan Compliance Mistakes to Avoid

Employers that sponsor group health plans are subject to many different compliance requirements under federal law. Keeping track of these various requirements can be challenging, even for the most attentive employers.

Mistakes can easily occur, which may trigger penalties, excise taxes, enforcement action or lawsuits.

10 Tips to Save on Health Care Costs in 2025

Healthcare costs have skyrocketed in recent years, and employees will continue feeling financial pressures throughout 2025. While you can’t control rising health care costs, you can take steps to curb your spending. This article outlines tips for reducing your health care spending.

Why Are Health Care Costs Rising in 2025?

Health care costs, and consequently employee benefit costs, have been growing at an alarming rate in recent years. For employees, that can mean higher premiums, deductibles and copayments. This article explores the key factors increasing health care costs in 2025.

Gag Clause Prohibition and Attestation Requirement

Effective in 2020, the Consolidated Appropriations Act, 2021 (CAA) prohibits health plans and health insurance issuers from entering into contracts with health care providers, third-party administrators (TPAs) or other service providers that contain gag clauses.