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Health & Welfare Plans Newsletter
February 19, 2026
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💼 4 New Job Opportunities
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[Official Guidance]
Text of IRS Publication 5945: Affordable Care Act (ACA) App for TCC (PDF)
"The purpose of the application is to request authorization to participate in electronic filing of the [ACA] Information Returns. The application currently supports the following: [1] Form 1094-B, Transmittal of Health Coverage Information Returns;
[2] Form 1095-B, Health Insurance Coverage; [3] Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns; [4] Form 1095-C, Employer-Provided Health Insurance Offer and Coverage. Complete the online ACA Application for TCC if your firm or organization meets the definition of any of the following roles: [1] Issuer ... [2] Transmitter ...
[3] Software Developer[.]" MORE >>
Internal Revenue Service [IRS]
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[Guidance Overview]
2027 ACA Out-of-Pocket Maximum Limits Released: Action Steps for Group Health Plan Sponsors
"[T]he HHS Notice of Benefit and Payment Parameters ... establishes the indexed out-of-pocket maximum limits that
apply to non-grandfathered group health plans beginning on or after January 1, 2027. Group health plan sponsors should evaluate these updated limits when finalizing plan designs for 2027, specifically regarding whether to increase out-of-pocket maximums or leave them unchanged." MORE >>
Milliman
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[Guidance Overview]
Decoding the PBM Reform Provisions of the 2026 Consolidated Appropriations Act
"Tucked within the Consolidated Appropriations Act, 2026 (HR 7148), signed on February 3, 2026, are structural mandates
that will reshape Pharmacy Benefit Manager (PBM) operations in Medicare Part D and the commercial sector by 2028. The legislation targets three primary pillars: revenue delinking, rebate transparency, and pharmacy network equity." MORE >>
Healthcare Economist
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[Guidance Overview]
Are There Transparency Requirements for Provider Directories?
"A group health plan is required to establish a database on its public website that contains a list with directory information for each health care provider and facility with which it has a direct or indirect contractual relationship for furnishing items and services....
[A] plan must establish a process to verify and update, at least once every 90 days, the information included in the website database." MORE >>
Thomson Reuters / EBIA
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Court Bars Insurer's Use of 'Tainted' Mental Health Claim Guidelines (PDF)
"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 >>
Thomson Reuters / EBIA
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New Wave of ERISA Litigation Targets Voluntary Welfare Benefits
"Despite the many unknowns ... these lawsuits will: [1] Provide in-depth briefing on core ERISA foundational questions.... [2] Push the boundaries of fiduciary duties and prohibited transaction rules under ERISA.... [3] Create a chilling effect on employers
offering voluntary benefits." MORE >>
Husch Blackwell
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The Value of Employer Health Plan Data in the Age of AI
"Claims data, eligibility files, engagement metrics, clinical insights, and behavioral signals fuel AI tools that promise efficiency, personalization, and cost optimization.... [M]ost employers don't actually know where their data is going, or how it's being used once it
gets there. That blind spot is becoming a bigger risk." MORE >>
Bolton
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Are Employers Getting Access to PBM Claims Data?
"The most effective time to secure strong data access rights is when negotiating a new contract, more specifically during a request for proposal (RFP) or similar competitive process. When multiple TPAs or PBMs are competing for your business, the balance of power shifts. Even
incumbents who previously claimed their 'hands were tied' often become far more flexible once they know another vendor could win the contract. Competition matters -- and it works." MORE >>
PLANSPONSOR; registration may be required
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Report Shows Weak Hospital and Health Plan Price Transparency in U.S.
"One of the most thorough analyses of the quality of hospital and health plan price transparency data got little attention when it was published last fall.... [T]he 185-page report from the Purchaser Business Group on Health (PBGH) ... shows the problems employers face when contracting with health insurers and hospitals for workers' health coverage." MORE >>
Association of Health Care Journalists
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GAO Report on Private Health Insurance: Provider Participation and Payments for Selected Services Before and After the No Surprises Act
"Among specialties likely to be affected by the No Surprises Act protections -- emergency medicine, radiology, anesthesiology, and air ambulance -- the percentage of in-network claims increased for three of the four specialties after the act took effect.... Payment
changes for the selected services largely reflected continuations of trends prior to the No Surprises Act taking effect." [GAO-107169 Feb. 19, 2026] MORE >>
U.S. Government Accountability Office [GAO]
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Employee Benefits Jobs
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Selected New Discussions |
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Is IRS Imposing Penalties for Errors on 1094-C or 1095-Cs?
"I know the ACA 'good faith' reporting relief ended in 2020, but I'm wondering if anyone knows it the IRS is actually assessing penalties for errors on a 1094-C or 1095-C filed after the relief ended?"
BenefitsLink® Message Boards
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Webinars, Podcasts and Conferences (Health & Welfare Plans) |
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Consolidation and Integration in Health Care: What It Means for Patients, Payers, and Policy
PODCAST
Kaiser Family Foundation
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Structuring Pension, Health, and Welfare Plans for Multinational Companies
March 27, 2026 WEBINAR
BARBRI
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Last Issue's Most Popular Items |
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Congress Expands Compensation Disclosure Requirements for Service Providers of Group Health Plans (PDF)
AON
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Proposed PBM Fee Disclosure Regs Are a Major Gamechanger
The Wagner Law Group
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Proposed PBM Transparency Regulations Issued (PDF)
AON
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BenefitsLink® Health & Welfare Plans Newsletter, ISSN no. 1536-9595.
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