Employee Benefits Compliance Blog

Webinar Recap: 2021 Year-End Employee Benefit Plan Compliance Checklist

National Employee Benefits Practice — Wed, 06 May 2026 13:35:56 GMT

Entering the fourth quarter of 2021, focus turns to open enrollment, holidays, and meeting company goals. However, when it comes to employee benefits, satisfying benefit plan compliance obligations should not be forgotten. These may include distributing safe harbor plan notices, meeting reporting obligations, and making required amendments.

CMS Finalizes Two Significant Medicare Part D Creditable Coverage Changes for 2027

National Employee Benefits Practice — Wed, 08 Apr 2026 15:32:26 GMT

Summary: On April 2, 2026, the Centers for Medicare and Medicaid Services (CMS), the federal agency governing Medicare, released a final rule for plan years beginning in calendar year 2027 impacting the Medicare Part D prescription drug benefit program (“final rule”). Click here for a CMS fact sheet summarizing the final rule.

Employers sponsoring group health plans should pay attention to two specific provisions within the final rule, outlined below:

Excluding account-based plans from the Notice of Creditable Coverage disclosure requirement for the following account-based plans:
- Health reimbursement arrangements (HRAs), including individual coverage HRAs (ICHRAs),
- Flexible spending accounts (FSAs), and
- Health savings accounts (HSAs))
Retiring the use of the current simplified determination method and codifying the revised simplified determination method, starting in 2027, for creditable coverage determination purposes.

Read on for more information and employer plan sponsor considerations.

Group Health Plan Fiduciary Lawsuit Survives Motion to Dismiss

National Employee Benefits Practice — Wed, 08 Apr 2026 14:09:41 GMT

Summary: A federal judge in New York recently allowed certain ERISA claims against an employer group health plan sponsor for alleged pharmacy benefit mismanagement to proceed past a motion to dismiss.

Read on for more information and employer group health plan sponsor considerations.

2026 Compliance Reminder: Upcoming Form 5500 Deadline for Calendar Year Plans

National Employee Benefits Practice — Wed, 25 Mar 2026 12:45:34 GMT

Employers sponsoring health and welfare benefit plans^[1] subject to the Employee Retirement Income Security Act of 1974 (ERISA) should take note of the upcoming Form 5500 filing deadline on July 31, 2026 for calendar year plans.

Another Season is Almost Here…Another Compliance Deadline Looms: RxDC Reporting

National Employee Benefits Practice — Thu, 05 Mar 2026 14:44:34 GMT

Summary: Spring is almost here, and with a new season comes a new compliance deadline looming for employers sponsoring group health plans: RxDC reporting for the 2025 reference year.

The Centers for Medicare and Medicaid Services (CMS) recently released updated RxDC reporting instructions for the 2025 reference year, which is due on June 1, 2026.

The updated instructions confirm no major changes from the previous version of RxDC reporting instructions other than updating the reference year from 2024 to 2025.

Read on for a general overview of RxDC reporting and employer group health plan sponsor next steps ahead of the June 1, 2026 deadline.

2026 Reminder: San Francisco HCSO Upcoming Reporting Deadline

National Employee Benefits Practice — Mon, 02 Mar 2026 13:47:03 GMT

Summary: Employers covered by the San Francisco Health Care Security Ordinance (HCSO) are required to submit the 2025 HCSO Annual Reporting Form by Friday, May 1, 2026.

The 2025 HCSO Employer Annual Reporting Form will be available on April 1, 2026, at this webpage. Covered employers who fail to make a timely submission of the HCSO Annual Reporting Form may be subject to a penalty of $500 per quarter.

Read on for more information and employer next steps.

New Jersey Family Leave Act Expands in July 2026

National Employee Benefits Practice — Fri, 20 Feb 2026 19:56:18 GMT

Summary: In one of his last acts before leaving office, outgoing New Jersey (NJ) Governor Phil Murphy signed Assembly Bill (AB) 3451 on January 17, 2026, amending the New Jersey Family Leave Act (NJ FLA) to apply to smaller employers and ease employee eligibility requirements.

AB 3451 also expands job protection for employees receiving benefits under NJ temporary disability insurance (TDI) and NJ family leave insurance (FLI) programs. The amendments in AB 3451 take effect on July 17, 2026.

Read on for more details and employer next steps ahead of the July 17, 2026 effective date.

HHS Releases Updated Model HIPAA Privacy Notice For Part 2 Records

National Employee Benefits Practice — Tue, 17 Feb 2026 21:39:00 GMT

As we previously reported here, the deadline for HIPAA^[1] covered entities, including employer-sponsored group health plans, to update their Notice of Privacy Practices (NPP) was February 16, 2026, to reflect changes in accordance with a 2024 Final Rule ("2024 Final Rule") regarding protections for substance use disorder (SUD) information in Part 2 program patient records.

PBM Reform: Recent Developments under the CAA 2026 & DOL Proposed Rule

National Employee Benefits Practice — Tue, 10 Feb 2026 15:46:29 GMT

Federal oversight of the pharmacy benefit management industry has intensified in recent years, culminating in the most sweeping federal legislative effort to regulate the industry to date with the enactment of the Consolidated Appropriations Act of 2026 (CAA 2026) on February 3, 2026. The CAA 2026, passed by Congress and signed into law by President Trump on the same day, funds various departments within the federal government.

HHS Increases Penalties for 2026

National Employee Benefits Practice — Mon, 02 Feb 2026 16:53:54 GMT

The Department of Health and Human Services (HHS) recently released inflation-adjusted increases for certain HHS-related penalties, including those for violations of the Health Insurance Portability and Accountability Act (HIPAA) rules and the Medicare Secondary Payer rules^[1].