"Form 1095-A is used to report certain information to the IRS about individuals who enroll in a qualified health plan through the Health Insurance Marketplace. Form 1095-A is also furnished to individuals to allow them to take the premium tax credit [and] to reconcile the credit on their returns with advance payments of the premium tax credit[.]" [Also available: 2025 IRS Form 1095-A]  MORE >>

Oct. 16, 2025. "What's New ... Employers no longer have to automatically send Form 1095-B to individuals. The requirement for furnishing the statement is met if the entity responsible for issuing the statements provides clear, conspicuous, and accessible notice on its website that an individual may request a copy of their statement and the copy is timely furnished. For this purpose, the statement is timely furnished if issued to the individual no later than 30 days after the date of the request."  MORE >>

"As a reminder, these annual adjustments are permissive, meaning employers/plan sponsors are not required to adopt [the] plan limit adjustments within their plan. If an employer/plan sponsor chooses to adjust their employee contribution/reimbursement amounts, they should reflect such changes within their accompanying document(s) that describe the plan(s)."  MORE >>

"The majority of federal courts that have addressed the issue of whether the NSA provides a private right of action have decided it does not and the Fifth Circuit is the only federal appellate court to rule on this issue. Without a circuit split, it will be surprising if the Court takes up this issue at this time." [Guardian Flight, L.L.C. v. Health Care Serv. Corp., No. 24-10561 (5th Cir. June 12, 2025; cert. pet. filed Oct. 8, 2025, No. 25-441)]  MORE >>

"Many employers confronted with hefty renewals increases for 2026 are looking at how best to offer GLP-1s for weight loss as a way to save money. Their appetite for change has brought forward many ideas, including utilization management, carve-out pharmacy benefit manager (PBMs), telemedicine, employee assistance programs (EAPs), wellness programs, and more. The biggest misconception about these programs is that they can be offered on a standalone basis to any employee, whether enrolled in the medical plan or not. But that's not typically the case."  MORE >>

"Plan changes generally occur every year in today's world, and those annual actions could trigger plan amendment procedures. Plan sponsors should review the changes taking place for the upcoming year and determine whether they need a plan amendment, SMM, or SMR. Some of these changes may also require distributing an updated Summary of Benefits and Coverage."  MORE >>

"Self-funded and fully insured employers are expected to cover the COVID-19 vaccines for eligible members at no cost to members without limitations on coverage based on medical indication or the requirement provider's prescription. This clarification was confirmed ... ahead of the CDC's formal adoption of the ACIP recommendations."  MORE >>

"The court noted that Ninth Circuit precedent calls for a narrow interpretation of ERISA Section 104 as it applies to plan document disclosure requests, explaining that not all contracts and other internal documentation dealing with plan administration are required to be disclosed.... [T]he ruling demonstrates that courts have wide latitude in awarding penalties in these situations, and that a plan's good faith response in accordance with relief granted due to a pandemic or other disaster can prove to be timely and penalty-averting behavior." [Zavislak v. Netflix, Inc., No. 24-4156 (9th Cir. Sep. 24, 2025; unpub.)]  MORE >>

"[T]he court emphasized that exhaustion applies 'across the spectrum of ERISA claims' -- including those alleging statutory violations or fiduciary breaches. While acknowledging that most other circuits do not require exhaustion for statutory ERISA claims, the Eleventh Circuit reaffirmed its unique position, holding itself bound by Mason until abrogated by the Supreme Court or by the court en banc." [Bolton v. Inland Fresh Seafood Corp. of Am., Inc., No. 24-10084 (11th Cir. Oct. 15, 2025)]  MORE >>