"The Departments and OPM extend the exercise of enforcement discretion ... under the relevant No Surprises Act provisions for any plan or issuer, or party to a payment dispute in the Federal IDR process, that uses a QPA calculated in accordance with the 2021 methodology, for items and services furnished on or after February 1, 2026, and before October 1, 2026 ... This exercise of enforcement discretion applies to QPAs for purposes of calculating patient cost sharing, providing required disclosures with an initial payment or notice of denial of payment, and providing required disclosures and submissions under the Federal IDR process."  MORE >>

6 pages; Mar. 2026. "The [IRS] is providing [this] sample plan to assist employers in establishing a qualified educational assistance program under section 127 of the Internal Revenue Code. The sample plan is intended to satisfy the requirements of section 127 of the Code and the underlying Treasury Regulations. An employer, in its discretion, may modify the sample plan and include additional plan provisions, provided that the requirements of section 127 of the Code and the underlying Treasury Regulations continue to be satisfied."  MORE >>

16 pages. "Inflation continues to drive high trend, pushing many plans beyond the upper thresholds of the de minimis ranges and, thus, out of compliance. Offsetting this dip, the 2027 maximum out-of-pocket (MOOP) limit increased sharply -- from $10,600 in 20262 to $12,000 in 2027 -- the largest MOOP jump to date. The proposed 2027 Notice of Benefit and Payment Parameters (NBPP) also suggests the possibility of even higher MOOP limits for Bronze and Catastrophic metal tiers up to 130%. The combined effects of these adjustments, and their implications for plan compliance and value, are examined further in the following sections."  MORE >>

"While the most immediate operational impact of this rule will likely fall on providers, payers, clearinghouses, and technology vendors, it also has important implications for employer sponsored group health plans. Group health plans are HIPAA covered entities for administrative simplification purposes, and plan sponsors should not assume that compliance is solely a vendor responsibility. Plan sponsors should begin working now with insurers, TPAs, and other business partners to assess whether systems, workflows, and service agreements will support the new electronic claims attachment standards by the 2028 compliance deadline."  MORE >>

"Because qualified transportation plans do not fall under either category (i.e., they are neither employee welfare benefit plans nor employee pension benefit plans), they are not employee benefit plans subject to ERISA's annual reporting obligation. Code Section 6039D previously imposed an annual information return requirement on certain 'fringe benefit plans,' but qualified transportation fringe benefit plans were not included."  MORE >>

"This case illustrates that a medical diagnosis alone does not automatically equate to a disability under Section 1557. An individual must demonstrate that the condition results in a substantial limitation of a major life activity under the ADA." [Whittemore v. Cigna Health & Life Ins. Co., No. 25-1248 (1st Cir. 2026)]  MORE >>

"While plaintiffs argue that employers are required to retroactively reimburse participants the total surcharge amount going back to the beginning of the plan year once a tobacco cessation course is completed and courts had generally agreed, now courts have increasingly held that employers have flexibility in wellness program design, including awarding premium discounts for program completion only prospectively as long as participants have at least one opportunity per year to qualify for the wellness program's reward and all other factors described above are met."  MORE >>

"77% of respondents expected health insurance sales to increase in the next year, 64% anticipated growth in group life insurance sales, and 62% forecasted more sales of supplemental health insurance products, such as hospital indemnity and critical-illness coverage. Yet nearly half of brokers cited administrative complexity as a core challenge to employers integrating supplemental health offerings into employee benefits packages."  MORE >>

"Employers interested in making contributions to Trump Accounts or facilitating employee contributions to Trump Accounts may wish to begin planning now to identify open questions as well as internal resources and assistance that may be needed from service providers, in particular if there is a desire to have a program in place under a cafeteria plan in time for open enrollment near the end of 2026."  MORE >>