The IRS has released updated limits and rules for Health Savings Accounts (HSAs), high-deductible health plans (HDHPs), Direct Primary Care Service Arrangements (DPCSAs), and excepted benefit HRAs. HSA contribution limits: Individual coverage: up to $4,500 per year. Family coverage: up to $9,000 per year. High-deductible health plan requirements: To qualify for an HSA, plans must…

Virginia has officially enacted a statewide Paid Family and Medical Leave (PFML) insurance program, creating new compliance obligations and strategic considerations for employers operating in the state. Below is a summary of the key provisions and timelines to be aware of: Program Overview Employer Contributions Key Dates Covered Leave Reasons Compliance Considerations What This Means…

Congressional focus on the underlying drivers of health care costs is accelerating, with increasing attention on hospital pricing, market consolidation, and structural inefficiencies that directly impact employer-sponsored health plans. The House Ways and Means Committee recently convened a hearing to examine these issues, featuring testimony from executives representing major U.S. health systems. In conjunction with…

With the start of a new year, there are several important reporting deadlines upcoming with respect to the federal Affordable Care Act (ACA), state individual mandate laws and W-2 reporting. W-2 Reporting: Employers must provide W-2s for the 2025 tax year to employees by January 31, 2026 (extended to the following business day if the…

In October, the departments of Treasury, Labor and Health and Human Servies (the “agencies”) issued FAQs clarifying how stand-alone fertility benefits may be offered under existing excepted benefit rules. These FAQs were released in response to Executive Order 14216, Expanding Access to In Vitro Fertilization, issued by the Trump administration in early 2025.  The FAQs do not change current rules or regulations. However, the agencies did indicate their intent to issue future regulations that could expand the ways fertility benefits can be offered as a type of limited…

Starting in 2026, the landscape of paid family and medical leave (PFML) is set to shift significantly. Thanks to the One Big Beautiful Bill Act (OBBBA), the Section 45S tax credit is now permanent—and more accessible. This change is intended to encourage broader adoption of PFML policies across U.S. workplaces. What’s Changing? OBBBA introduces several…

The Internal Revenue Service (IRS) has released Revenue Procedure 2025-32 announcing new 2026 inflation-adjusted limits for Health and Dependent Care FSAs and qualified Commuter Benefits. This is in addition to the annual limits previously announced in Revenue Procedure 2025-19 (previous alert). 2026 Health FSA Limits: 2026 Dependent Care FSA Limit: 2026 Commuter Benefit Limits: Client…

The Consolidated Appropriations Act of 2021 (CAA) prohibits group health plans and issuers from entering into agreements with health care providers, third party administrators (TPAs) or other service providers that contain “gag clause” provisions which directly or indirectly restrict the plan or insurer from:  Gag Clause Prohibition Compliance Attestation (GCPCA) Due by December 31:  Group…

The IRS recently issued Revenue Procedures 2025-25 and 2025-26 announcing the 2026 affordability threshold (contribution percentage) for employer-sponsored health plans and adjusted shared responsibility penalty amounts under the Affordable Care Act (ACA).    Background:  Under the ACA, applicable large employers (ALEs) – those with 50 or more full-time equivalent employees – must offer minimum essential coverage…

On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (OBBB) into law. The legislation includes several key changes affecting employee benefit plans, including expanded flexibility for telehealth and direct primary care benefits, and enhancements to Health Savings Accounts (HSAs) and Dependent Care Flexible Spending Accounts (DCFSAs). With the exception of the…