Year-End Compliance Adjustments for Group Health Plans in 2025 and 2026
Year-End Overview and Forthcoming Compliance Adjustments in Group Health Plans
As 2025 concludes, plan sponsors must evaluate their compliance activities and prepare for upcoming regulatory obligations in 2026. This overview provides a concise summary of key compliance topics relevant for both 2025 and 2026. From regulatory changes to IRS filing obligations, staying updated is essential for maintaining compliance.
Regulatory Changes in 2025
In 2025, non-grandfathered group health plans were required to expand their coverage to include three specific vaccines: poliovirus, RSV, and mpox. Additionally, there was a mandate to provide broader coverage for anxiety disorder screenings, encompassing adults aged 64 and younger, as well as pregnant and postpartum women.
Alterations in Compliance for 2026
Looking ahead to 2026, non-grandfathered plans must include patient navigation services for breast and cervical cancer screenings, along with additional imaging services. Coverage must extend to RSV, pneumococcal, and influenza vaccines. Furthermore, plan sponsors and applicable large employers (ALEs) can now post notices regarding the availability of Forms 1095-B and 1095-C on their websites. For 2025 coverage reported in 2026, this notice should be posted by March 2, 2026, and remain accessible until October 15, 2026.
IRS Filing Obligations and Non-Quantitative Treatment Limitation Analysis
By March 31, 2026, electronic filings require plan sponsors to submit Forms 1095-B or 1095-C if there are at least 10 returns. For paper filings, the due date is March 2, 2026. The IRS offers guidance on completing these forms. Under the Consolidated Appropriations Act of 2021, plan sponsors must conduct a comparative analysis of their non-quantitative treatment limitations (NQTLs). While additional NQTL-related compliance requirements announced in 2024 will not be enforced, adherence to the CAA’s requirements is crucial.
HIPAA and the SECURE 2.0 Act
By February 16, 2026, plan sponsors must update HIPAA Privacy Notices to comply with regulations under 42 CFR Part 2, concerning substance use disorder records. The SECURE 2.0 Act mandates, beginning in 2026, that participants in defined contribution plans who earned over $150,000 in FICA wages in 2025 and make age-based catch-up contributions do so on a Roth basis. These changes take effect on January 1, 2026, with further rules implemented on January 1, 2027.
In summary, addressing amendments from various legislative Acts, including the CARES Act, Miner’s Act, Relief Act, SECURE Act, and SECURE 2.0 Act, is critical. Meeting these deadlines ensures compliance and prepares plan sponsors for potential regulatory changes in the future.