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Health & Welfare Plans Newsletter

October 6, 2025

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[Guidance Overview]

Revised CMS Key Dates for Calendar Year 2025: Qualified Health Plan Data Submission and Certification, Rate Review, and Risk Adjustment (PDF)

Rev. Oct. 6, 2025. "This document summarizes key dates for calendar year 2025 regarding some activities and policies that are outlined in other documents ... originally published on December 31, 2024 ... This document revises certain key dates listed in the December 31, 2024 version in response to City of Columbus v. Kennedy[.]"  MORE >>

Centers for Medicare & Medicaid Services [CMS], U.S. Department of Health and Human Services [HHS]

[Guidance Overview]

California Again Expands Reasons Employees Can Use Job-Protected Paid Sick and Safe Time, Unpaid Leave

"This year's amendments ... effective January 1, 2026 ... allow employees to use leave if they or a family member are a victim of certain crimes and are attending judicial proceedings related to that crime ... [T]he amendments -- effective on October 1, 2025 -- revise the paid leave law to incorporate by reference covered uses that already exist under the unpaid leave law:"  MORE >>

Littler

[Guidance Overview]

Massachusetts Announces 2026 PFML Contribution Rates, Maximum Weekly Benefits

"As of Jan. 1, 2026, the benefit contribution rate remains at .88% of eligible wages for all employers.... Additionally, on Jan. 1, 2026, the maximum weekly benefit will increase from $1,170.64 to $1,230.39."  MORE >>

Jackson Lewis P.C.

[Guidance Overview]

Employer Guide to Washington State PFML Changes Effective Jan 1, 2026

"Smaller employers ... will be required to begin implementation of job protection for employees over a three-year period ... [T]here is also a new stacking mechanism allowing (but not requiring) employers to count FMLA leave toward the total amount of leave entitled to job protection under the WA PFML, if the employee was eligible for WA PFML but did not apply for and receive it.... [E]mployers must provide a written notice within five business days of the employee's initial request for or use of FMLA leave, whichever comes first, and then monthly thereafter for the remainder of the employer's FMLA 12-month period."  MORE >>

Sequoia

Fiduciary Risks in Pharmacy Benefits: A Checklist for Plan Sponsors

"[1] Conduct an independent legal review.... [2] Consider a request for proposals (RFP).... [3] Identify above-market pricing and hidden revenue.... [4] Renegotiate or implement new terms.... [5] Audit for overcharges.... [6] Educate your fiduciaries. "  MORE >>

Nixon Peabody LLP

Questions to Ask Your Employee Benefits Broker at Renewal

"[1] Can you present a strategy and timeline for alternative vendor options? ... [2] What cost-saving strategies can we deploy this year with minimal disruption? ... [3] Which digital health or telehealth solutions should we consider for our population? ... [4] What high-performance or alternative network options are available? ... [5] How do we measure your performance and hold you accountable? ... [6] What's the renewal timeline and what milestones should we hit together?"  MORE >>

Nava

Things to Know About Employer-Provided Coverage (PDF)

"A strong majority of consumers (63%) with employer- provided coverage are satisfied with their current coverage.... On average, employers pay 84% of employees' health coverage premiums for a single person, and 75% for a family.... Nearly 1 in 4 Americans -- 41 million people -- received mental health support in 2020 through their employer coverage.... A strong majority of voters (63%) support the current tax treatment of employer-provided coverage."  MORE >>

AHIP

Is Connecticut's Massive Trove of Healthcare Data Useful?

"Containing over two billion claims, the [All Payer Claims Database (APCD)] is big, complex, and expensive to maintain ... What the data lacks ... is claims for self-insured plans, which comprise the largest group of consumers in the state ... [T]he data appears to largely be used by [Connecticut's Office of Health Strategy (OHS)] for their various analyses on healthcare costs ... and for consumer dashboards meant to allow users to compare costs for services at multiple in-state providers."  MORE >>

Connecticut Inside Investigator

Addressing Cancer Care Gaps to Improve Cost and Clinical Outcomes: What Health Plans Need to Know (PDF)

14 pages. "To truly take control of cancer and its costs, health plans must work to close care gaps for their members -- starting before a person becomes sick, spanning the course of diagnosis and treatment, and extending long into recovery."  MORE >>

American Cancer Society via AHIP

No Surprises Act Arbitration Has Been a Bonanza for a Few Providers

"Across the two years for which CMS has made data available, providers initiated at least 85% of disputes and won 82% of cases. Five PE groups accounted for almost 60% of the filed disputes.... One recurring complaint of providers is the difficulty of obtaining arbitrated payments. In 2024, a physician association reported that 24% of IDR payments received by members either were not paid within the required time frame of 30 business days or were not paid in full."  MORE >>

Healthcare Financial Management Association [HFMA]; registration may be required

[Opinion]

So You Want to RBP?

"[Reference-based pricing (RBP)] isn't a toggle to the easy bottom. It's an entirely new operating system. It changes incentives, processes, and psychology. It's a direct assault on the two most powerful stakeholders in the largest segment of America's economy (healthcare): insurers and hospital chains. It works when you do it right, and it blows up when you wing it."  MORE >>

Craig Gottwals via Substack; registration may be required

Press Releases

PSCA Partners with Knowa to Launch Revolutionary Single Intelligent Hub for 401(k) and 403(b) Plan Administration

PSCA [Plan Sponsor Council of America]

Transamerica, Fiducient Advisors to Launch 403(b) Pooled Employer Plan

Transamerica

Webinars, Podcasts and Conferences
(Health & Welfare Plans)

Health and Welfare Benefit Plans National Institute 2025

October 27, 2025 in DC

American Bar Association Joint Committee on Employee Benefits [JCEB]

Last Issue's Most Popular Items

Health and Welfare Plan Lunch Group, October 2025 (PDF)

Alston & Bird

Good News and Bad News in the Priority Guidance Plan from Treasury and IRS

Groom Law Group

Minnesota Paid Leave Starts January 1, 2026: Are You Ready?

Faegre Drinker

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BenefitsLink® Health & Welfare Plans Newsletter, ISSN no. 1536-9595.

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