EMPLOYEE BENEFITS COMPLIANCE UPDATES
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Q1 2025 | Q2 2025 | Q3 2025  | Q4 2025 


Q4 2025

October

National

  • Fertility Services as Excepted Benefits
  • Gag Clause Attestation Due December 31, 2025
  • Immunization Schedule Updated by the CDC
  • 2026 Cost of Living Adjustments

State & Local

  • California Enacts PBM Reform Law
  • California Redefines Approach to Preventive Care Standards
  • Illinois PBM Law Takes Effect January 1, 2026
  • Illinois Mandates Fertility Benefits and Dependent Coverage for Parents
  • Massachusetts HIRD Reporting Due December 15, 2025
  • Massachusetts Paid Family Leave 2026 Contributions and Benefits
  • New York Paid Family Leave 2026 Contributions and Benefits
  • Texas’ Woman and Child Protection Act

November

National

  • New PCOR Fee Announced
    Final 2025 ACA Reporting Instructions and Forms Issued

State & Local

  • No state or local updates

December

National

  • Initial Guidance on Employer Contributions to Trump Accounts
  • Guidance on HSA Provisions in OBBBA

State & Local

  • Delaware Amends Paid Family and Medical Leave Law Again
  • Disability and Family Leave Amounts

Q3 2025

July

National

  • IRS Announces 2026 ACA Affordability Indexed Amount
  • One Big Beautiful Bill Act Signed into Law
  • HHS Revises Out-of-Pocket Maximum Limits for 2026
  • Deal Reached to Simplify Prior Authorizations

State & Local

  • California Delays Implementing Mandated Fertility Benefits
  • North Carolina Enacts PBM Law
  • Texas Legislature Extends Period for Newborn Enrollment
  • New Texas Mandated Benefits for 2026

August

National

  • Departments Extend Enforcement Relief for the No Surprises Act

State & Local

  • San Francisco HCSO Expenditures and Reporting Update for 2026
  • Connecticut Expands Leave to Certain School Employees
  • Delaware Amends Paid Family and Medical Leave Law
  • Washington Expands PFML Protections

September

National

  • 2025 MLR Rebate Checks to Be Issued Soon to Fully Insured Plans

State & Local

  • Washington State Expands EHBs Starting January 1, 2026

Q2 2025

April

National

  • New Executive Order Addresses Lowering Drug Prices
  • Medicare Part D Creditable Coverage Determination Update

State & Local

  • Another Delay for Maryland’s Paid Family and Medical Leave
  • Massachusetts Enacts Enhanced PBM Law
  • Virginia Implements Guidance for Excepted Benefits Policies

May

National

  • House Passes Reconciliation Package
  • Enforcement Relief Coming for MHPAEA Final Rule (Updated)
  • 2025 Updates to Women's Preventive Services Guidelines
  • Executive Order Targets Prescription Drug Pricing 
  • 2026 Inflation Adjusted Amounts for HSAs, HDHPs, and EBHRAs
  • 2024 RxDC Reporting Reminder

State & Local

  • WA Cares Fund Update
  • Reminder — Seattle Ancillary Hotel Business Health Expenditures

June

National

  • Privacy Rule Addressing Reproductive Health Vacated
  • Updated article – House Passes Reconciliation Package
  • Proposed Changes to Machine-Readable File Requirement
  • 2025 PCOR Fee Filing Reminder for Self-Insured Plans

State & Local

  • Update on the End of Indiana’s 2025 Legislative Session
  • New York City Issues Guidance for Prenatal Leave
  • Texas Potentially Eases Premium Liability

Q1 2025

January

National

  • New NSA and Gag Clause Guidance Issued
  • Update on the Johnson & Johnson ERISA Fiduciary Lawsuit
  • DOL Penalties Increase for 2025
  • IRS Issues Guidance on State PFML Tax Treatment
  • 2025 Federal Poverty Guidelines Announced
  • Medicare Part D CMS Notification Reminder
  • Fixed Indemnity Notice Invalidated by District Court
  • State Health Coverage Reporting Requirements for CY 2024

State & Local

  • No state or local updates

February

National

  • New Guidance Provides Additional Details on Reporting Relief
  • Tobacco Surcharges Face Growing Scrutiny in Recent Lawsuits

State & Local

  • Michigan Amends the Earned Sick Time Act and Minimum Wage
  • Updated article: Minnesota Passes Paid Family and Medical Leave Law

March

National

  • Key Considerations for Plan Sponsors in Proposed HHS Rule
  • New Executive Order Addresses Price Transparency Rules

State & Local

  • Alaska's New Paid Sick Leave Law
  • Reminder: San Francisco HCSO Reporting Due May 2, 2025
  • Massachusetts Releases 2026 MCC Limits
  • Ohio Legislature Passes Madeline's Law Covering Hearing Instruments
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