"This document extends the comment period on the Department's Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure proposed rule ... [which] was published in the Federal Register on January 30, 2026, with a comment deadline of March 31, 2026. On February 3, 2026, the Consolidated Appropriations Act, 2026 amended ERISA to add several provisions relating to providers of pharmacy benefit management services. Consequently, the Department is extending the comment period for an additional 15 days, to April 15, 2026, to allow interested persons to address whether the rule should be adjusted due to these new statutory provisions." MORE >>
"Long insulated from meaningful disclosure obligations, PBMs now face a dramatically different regulatory environment as three major developments converged within days of each other ... Together, these actions create a transition toward PBM transparency." MORE >>
"Most of the CAA 2026 changes become effective no earlier than 30 months after the effective date of the new law. Accordingly, for a calendar-year plan, most changes are effective January 1, 2029. However, CAA 2026 also revises the ERISA prohibited transaction exemption rules and those changes appear to be effective as of the date of the CAA 2026's passage.... PBMs, plan sponsors and others may feel pressure to implement business changes earlier -- especially in light of the FTC/ESI Settlement." MORE >>
42 pages. "Employment-based health coverage remained the dominant source of health insurance for privately insured adults, with six in 10 receiving coverage through their own job.... More than three-quarters of enrollees had a deductible for medical care, including 70 percent of traditional plan enrollees.... Enrollment in high-deductible health plans declined slightly in 2025, and enrollment in consumer-directed health plans and health savings accounts (HSAs) appeared to be relatively stable." MORE >>
"LIMRA forecasts slower in‑force premium growth for life and disability products through 2028. Life insurance in‑force premium growth is expected to fall below historical averages, while long‑term and short‑term disability premiums should remain closer to recent norms.... Employers still need competitive benefits packages to attract and retain top talent. Workers increasingly value flexibility, well‑being, and financial security. Advances in technology -- from data analytics to AI -- are enabling more personalized benefit recommendations and communications." MORE >>
"This article examines the CAA in the context of other federal and state efforts to regulate PBMs, then offers recommendations on additional steps Congress and federal agencies could take in this sphere." MORE >>
"Certain services performed in connection with a colonoscopy performed as a preventive screening procedure pursuant to the USPSTF recommendation must be covered without cost-sharing where the services are an integral part of the colonoscopy (subject to reasonable medical management).... Your plan must also cover, without cost-sharing, a follow-up colonoscopy conducted after a positive non- invasive stool-based test or direct visualization test." MORE >>
"CMS proposes to prohibit issuers from including routing non-pediatric dental services as EHB.... This is a reversal of the policy finalized in the 2025 Payment Notice ... CMS had stated that, beginning in PY 2025, covered benefits in a State's EHB-benchmark plan are EHBs and, thus, do not require defrayal by the State. In this proposed rule, CMS notes that it has reevaluated this policy.... The proposal to certify non-network plans as QHPs is both a reversal and an expansion of previous policies." MORE >>
38 pages. "This 2027 Draft Letter provides updates on operational and technical guidance for the 2027 plan year for issuers seeking to offer qualified health plans (QHPs), including stand-alone dental plans (SADPs), in the Federally-facilitated Exchanges (FFEs) or the Federally-facilitated Small Business Health Options Programs (FF-SHOPs).... The 2027 Draft Letter focuses on guidance that has been updated for the 2027 plan year[.]" MORE >>
"[EBSA] recently announced changes to their enforcement priorities for 2026. These changes represent the most significant shift in EBSA's enforcement priorities in recent years.... EBSA's enforcement priority shift reflects the agency's assessment of where American workers face the greatest risks to their retirement security and healthcare benefits. By focusing resources on cybersecurity threats, mental health access barriers and criminal misconduct, while pulling back from areas with new participant protections, EBSA aims to deliver better outcomes for those covered by employer-sponsored benefit plans." MORE >>
"Every year the state's official health insurance marketplace under the [ACA], the Massachusetts Health Connector, sets the maximum deductibles and out-of-pocket maximums for individual and family levels. Employers are not required to provide MCC, but ensuring their plans are compliant will help employees avoid individual penalties." MORE >>
"Mercer projects the 2027 inflation-adjusted amounts for health savings accounts (HSAs), high-deductible health plans (HDHPs), and excepted-benefit health reimbursement arrangements (HRAs) will increase from 2026 levels." MORE >>
"Plaintiffs' firms have begun applying the excessive fee playbook to health plans ... At the same time, group health plans remain under scrutiny from the [DOL].... In the current regulatory enforcement and litigation environment, revisiting fiduciary governance practices, particularly around service provider selection, fee monitoring, and oversight, can reduce exposure and strengthen overall fiduciary compliance." MORE >>
"The passage of HR 7148 represents the most significant federal intervention into pharmacy benefit management practices in decades.... The [DOL] also recently issued proposed rules that add similar transparency obligations. For employers sponsoring group health plans, these changes carry substantial compliance obligations, fiduciary considerations and operational implications that will require proactive planning. Employers should also be on alert that the changes will likely result in PBM contract renegotiations." MORE >>
"The fourth quarter of 2025 saw a flurry of mostly routine or minor developments in the paid family and medical leave space. California and New York City expanded their paid sick and safe leave laws. California and Illinois imposed restrictions on pharmacy benefit manager activities. California passed two laws: one that will ultimately limit the use of prior authorizations and another that will increase the coverage of its benchmark plan to include fertility services. Other noteworthy developments occurred in Iowa, New Mexico, and Washington." MORE >>
"[1] Innovative new plan designs ... [2] A resurgence of high-deductible health plans ... [3] Use of an integrated benefits platform ... [4] Biosimilars gaining traction ... [5] Continuing pediatric mental health cost challenges." MORE >>
12 pages. "The notice includes important proposed rules and parameters for the operation of the individual and small group health insurance markets in 2026 and beyond. This paper summarizes key provisions in the proposed notice and maximum out-of-pocket cost information recently released by HHS. Comments are due no later than March 13, 2026." MORE >>
"This report describes current law and applicable regulations and guidance, specifically with regard to how the PTC and CSR requirements apply in 2026." [R44425 Feb. 19, 2026] MORE >>
"A split three-judge panel of the U.S. Court of Appeals for the Fifth Circuit ruled that a federal district court should decide whether Aramark can proceed with its lawsuit against Aetna or must resolve the dispute through arbitration. According to the court's ruling, the arbitration clause is sufficiently ambiguous to be subject to court review." [Aramark Serv. v. Aetna Life Ins., No. 24-40323 (5th Cir. Dec. 18, 2025)] MORE >>
"Louisiana is among the worst-performing states in maternal and infant health outcomes. So New Orleans is trying to catch health issues early -- and get families off to an easier start -- by adding health visits during the crucial first months of life. The hope is that health outcomes can be improved by returning to the old-fashioned medical practice of house calls.... Research on North Carolina's program found that every $1 invested in the program saved $3.17 in health care billing before the child turned 2." MORE >>
"The prevalence of ASD has increased significantly, with diagnoses rising from 1 in 150 children in 2000 to 1 in 31 children in 2022.... Employers face escalating costs and unmet employee needs due to care gaps and delays in diagnoses. By addressing these challenges, employers can manage financial risks while providing meaningful and sustainable support to employees and their families." MORE >>
"Part 2 examines the newest fronts in ERISA litigation, including the surge in forfeiture and voluntary benefits lawsuits ... Also addressed is the growing role of documentation, engaged oversight, and defensible process as courts continue to emphasize prudence over outcomes. This installment also looks at the evolving regulatory environment ... and what that could mean for plan advisors and sponsors. Ultimately, Part 2 focuses on practical steps fiduciaries can take now to strengthen governance, tighten documentation, and reduce litigation exposure." MORE >>
"CGT users represent fewer than 0.1% of the enrollee population but account for approximately 0.5% of total spending. This includes both the cost of CGTs and spending on other health services.... Impact on High-Cost Claimants: Among enrollees in the top 1% of total health care spenders, just 0.58% used CGTs. However, these individuals accounted for 1.6% of spending within that top spending group. While the share is small, it signals that CGTs can meaningfully impact spending patterns among high-cost claimants." MORE >>
"The average plan could pay for approximately one year and four months of benefits and expenses with its net assets, an increase of approximately one-and-a-half months of total expenses from last year.... On a per member basis, expenses increased by 5.8% and total contribution income increased by 3.2% year over year. Over 80% of plans had a net gain in 2023, a significant improvement compared to both 2021 and 2022, when plan income was greater than expenses for about half of plans." MORE >>
"In the latest installment of a long-running dispute, a federal trial court has again prohibited a large insurer from using internal claim guidelines that were inconsistent with generally accepted standards of care (GASC) for the treatment of mental health and substance use disorders.... The trial court has now revised its decision, holding that the plans did not require the insurer to approve benefits for all services that were consistent with GASC but did require, as a condition of coverage, that services be consistent with GASC.... Thus, the willful and systematic use of the guidelines violated ERISA's duty of loyalty and care toward the participants ... The court permanently barred the insurer from using the flawed guidelines for ERISA-governed plans and will retain jurisdiction for five years, during which any guidelines adopted by the insurer must accurately reflect GASC and any applicable state law." [Wit v. United Behavioral Health, No. 14-2346 (N.D. Calif. Feb. 3, 2026)] MORE >>
