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More Employers Offer Caregiver Leave as Need Mounts

A new survey found that many employers plan to add or expand caregiver leave as they contend with workforce burnout, changing family dynamics and competition for talent.

According to WTW’s “2025 Absence, Disability and Medical Leave Survey,” caregiver leave is expected to see the fastest growth of any leave benefit over the next two years, despite only a handful of states requiring it by law. The shift comes as caregiving demands intensify across a multigenerational workforce. Many employees juggle work while caring for aging parents, children or other dependents, often with limited financial or workplace support.

Employers are finding that caregiver leave can help reduce stress and burnout, improve morale and productivity and support retention in a tight labor market where replacing workers is increasingly expensive.

What the WTW survey found

  • 73% of employers plan to enhance leave programs over the next two years.
  • 39% of employers expect to offer caregiver leave within two years, up from 22%.
  • Employers cite improving employee experience (67%) and strengthening attraction and retention (60%) as the top reasons for expanding leave benefits.
  • 49% of employers identify leave program administration as their biggest challenge, followed by system integration and workforce coverage.

The importance of caregiver leave

Caregiver leave addresses a growing gap for a workforce that increasingly spans multiple generations. Nearly one quarter of U.S. adults are part of the so-called “sandwich generation,” caring for both children and aging parents, according to another report. These employees often provide about 20 hours of unpaid care per week and may spend $10,000 to $11,300 a year out of pocket to support family members.

Although caregiver leave may qualify under the Family and Medical Leave Act (FMLA), it is typically unpaid unless employers offer wage replacement. That financial strain can increase stress and burnout, pushing some caregivers to reduce their hours, change jobs or leave the workforce entirely.

From a business standpoint, caregiver leave can help mitigate turnover risk. Replacing an employee can cost about 30% of annual pay. While caregiver leave will not eliminate turnover, it can lower the risk that employees leave because of caregiving responsibilities.

How employers can implement caregiver leave

Employers considering caregiver leave often start by integrating it into their existing leave or paid time off structures.

Common approaches include offering a defined number of paid leave days per year, allowing caregiving use of banked personal time off or layering caregiver leave on top of state paid family leave programs.

Best practices include:

  • Defining caregiving broadly to cover children, parents, spouses, domestic partners and other dependents.
  • Coordinating caregiver leave with FMLA and state programs to avoid duplication and ensure compliance.
  • Setting clear eligibility and documentation standards while keeping the process simple for employees.
  • Training managers to handle workload planning and employee conversations.

Overcoming administrative and operational challenges

Administration remains one of the biggest barriers to expanding caregiver leave. Challenges include coordinating multiple leave programs, maintaining multistate compliance and managing staffing as leave usage increases.

To address these issues, many employers are:

  • Outsourcing leave administration to specialized vendors.
  • Standardizing policies and systems across locations.
  • Using technology to support routine leave management.
  • Monitoring utilization to ensure caregiver leave is accessible and free of stigma.

The takeaway

As caregiving responsibilities continue to affect a growing share of the workforce, caregiver leave is emerging as a practical, targeted benefit that supports employees while helping employers attract and retain talent in a competitive labor market.

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Uncategorized

The Importance of Reconciling Your Employee Benefits

Employee benefits are one of the largest and most complex expenses many employers manage — and they also include strict fiduciary obligations.

Yet many organizations assume that once open enrollment ends and payroll deductions are set, everything will continue to run smoothly. In reality, enrollment changes, life events, terminations, plan switches and billing delays routinely create discrepancies that can quietly cost both employers and employees money.

That’s why it’s important for employers to conduct regular reconciliations of their benefits offerings to confirm that:

  • Employees are enrolled in the plans they chose,
  • Payroll deductions reflect the correct coverage tier and contribution amount, and
  • Carrier billings are accurate.

Key areas of the benefits reconciliation process

Gather information — Reconciliation begins with assembling accurate, matching data for the same coverage period. Employers typically need carrier invoices, payroll deduction reports and enrollment records from their HR or benefits administration system.

Using data from different periods can create discrepancies, so timing matters.

Compare enrollment and invoices — Employers should compare the list of employees and dependents on carrier invoices with internal enrollment records. This step helps identify common issues such as terminated employees still being billed, active employees missing from invoices or dependents incorrectly listed. It also confirms that employees are enrolled in the correct plans.

Verify payroll deduction amounts — Next, payroll deductions should be reviewed in comparison against plan rates and contribution structures.

This includes checking employee-only versus family tiers, employer subsidies and any midyear changes triggered by qualifying life events. Even small per pay period errors can add up over time if left uncorrected.

Investigate issues — Discrepancies are common and do not necessarily indicate a system failure. New hires may not yet appear on invoices, plan changes may not have been processed in time or terminations may have missed the carrier cutoff date.

Each issue should be investigated, corrected and communicated to the appropriate party — whether that is payroll, HR or the carrier.

Document findings and resolutions — Finally, employers should document findings and resolutions. This may involve adjusting future payroll deductions, requesting invoice credits or corrections from carriers or updating enrollment records.

Clear documentation creates an audit trail and helps prevent recurring errors.

Reconciliation protects firms and staff

Regular reconciliation protects budgets by preventing “premium leakage” — paying for coverage that no longer applies or deducting insufficient amounts from employee paychecks.

For example, if an employee is terminated and not removed from enrollment in a timely manner, the company will be held financially responsible for paying 100% of benefit premiums. Reconciliation would catch this issue.

Reconciliations also help mitigate potential legal issues and reduce the risk of employee dissatisfaction when errors surface months later and large corrections are required. From a governance perspective, reconciliation supports data integrity and financial accuracy across HR, payroll and finance functions.

Best practices for employers

Conduct regular audits — Monthly reconciliation is widely considered a best practice, especially for medical, dental and vision plans.

Use automation wisely — Many employers now use payroll or benefits administration tools that automate comparisons between enrollment, deductions and invoices, reducing manual work and improving accuracy.

Consider third-party support — There are vendors that specialize in benefits reconciliation and invoice auditing. These services can be valuable for organizations with multiple carriers, frequent employee changes or limited internal resources.

Include COBRA and other benefits — Reconciliation should extend beyond active employee plans. Employers should also confirm that COBRA participants are billed correctly and that voluntary and ancillary benefits are handled with the same discipline.

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Uncategorized

How Health Insurers Are Trying to Rein in Costs Without Cutting Value

Employers are grappling with another year of steep increases in group health plan premiums due to medical cost inflation, higher utilization and rising drug prices.

At the same time, health insurers can no longer shift additional costs to employers and employees through higher deductibles or narrower networks.

Instead, many insurers are pursuing structural changes designed to control long-term costs while improving care quality and member experience.

Interviews with health plan executives and recent industry reporting point to a common theme: reducing avoidable care, simplifying administration and investing earlier in health to prevent expensive problems later.

Employers and their staff can benefit from these strategies, which are increasingly being built into plan design, provider networks and care management programs that influence both premiums and employees’ out-of-pocket costs.

Preventive and personalized care

A central focus for many insurers is expanding preventive care and making it easier for enrollees to engage with their providers before health issues worsen. Executives at plans such as Humana and Highmark Wholecare, in a recent roundtable with the news website Becker’s Payer Issues, emphasized coordinated care models that connect primary care, specialists and support services around the individual.

These models rely on data and digital tools to identify care gaps early, such as missed screenings or unmanaged chronic conditions. Members may receive targeted reminders, care manager outreach or digital coaching to stay on track. For employers, this approach can translate into:

  • Fewer high-cost claims tied to late-stage disease
  • Fewer avoidable hospitalizations
  • Fewer emergency department visits

Employees benefit from clearer guidance, easier navigation of benefits and more proactive outreach instead of reacting to health issues once they become serious and costly.

Cost containment through innovation and collaboration

Insurers are increasingly rethinking how care is paid for and delivered. Many are expanding value-based payment arrangements that reward providers for keeping patients healthy rather than paying for higher volumes of services.

Under these arrangements, insurers and providers share data and align financial incentives around outcomes and the total cost of care.

Plans are also using predictive analytics and artificial intelligence to identify members at higher risk of complications and intervene earlier through care coordination, remote monitoring or alternative sites of care.

For employers, this can help slow medical cost growth over time without eroding access to care for their employees.

Administrative efficiency and transparency

Health plans are investing in modernized claims systems, real-time eligibility and claim validation and more streamlined prior authorization for routine or evidence-based care.

Some plans are reducing or reforming prior authorization requirements where data shows little value, while using technology to make remaining reviews faster and more predictable. Insurers are also working to improve transparency around costs and benefits, helping members better understand service costs and coverage before care is delivered.

For employers, lower administrative costs can help moderate premium growth and reduce HR workload tied to billing disputes and employee questions. Employees may benefit from fewer delays, clearer explanations of benefits and less confusion when accessing care.

What this means for employers

While no single initiative will eliminate health care cost pressure, insurers argue that combining preventive care, value-based payment and administrative simplification offers a more durable path forward.

Employers evaluating plan options may want to work with us to assess how their carriers are implementing these or similar strategies and how they measure success.

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Uncategorized

Voluntary Benefits Lawsuits Add Fiduciary Concerns for Employers

Plaintiff’s lawyers are breaking new ground by suing employers for allegedly failing in their fiduciary duties to manage their voluntary benefit plans, including dental, vision, accident insurance, critical illness, cancer and hospital indemnity benefits.

These class action lawsuits typically allege that employers exercise sufficient control over these plans to trigger fiduciary duties under the Employee Retirement Income Security Act (ERISA) and that those duties were breached. Once ERISA applies, employers can face claims tied not just to plan design, but to the prudence of benefit selection and monitoring.

If these lawsuits gain traction, they may open a new category of potential liability tied to benefit offerings that many employers have historically overlooked.

At the center of the litigation is the claim that certain voluntary benefit arrangements are not exempt from ERISA, either because they fail to meet the voluntary plan safe harbor or because employers exercise sufficient control to trigger fiduciary duties.

Five areas drawing scrutiny

Four recent class action lawsuits filed against large employers include similar allegations that the employers and their benefits brokers breached ERISA fiduciary duties by allowing excessive commissions, failing to monitor insurers and brokers and engaging in conflicted arrangements within employer-sponsored voluntary benefits programs.

Each of these companies was sued by an employees’ union benefit or welfare plan:

  • United Airlines
  • Laboratory Corporation of America
  • Community Health Systems
  • Allied Universal

Key areas of alleged exposure include:

1. Benefits selection processes — Employers are being accused of failing to run competitive requests for proposals, benchmark offerings or document why certain carriers or products were chosen. A casual selection process that keeps the same plan each year can be portrayed as imprudent once fiduciary standards apply.

2.  Contracts — Agreements with insurers, brokers and enrollment vendors are under the microscope. Vague terms, unclear delegation of responsibilities or contracts that fail to spell out fiduciary status can make it harder for employers to defend their role as plan sponsors.

3. Broker and vendor compensation provisions — Embedded commissions, overrides and incentive payments are a central theme in the lawsuits. Plaintiffs argue that employers failed to monitor compensation levels or allowed conflicted arrangements that inflated employee premiums.

4. Premium levels — Even when employees pay the full cost, plaintiffs contend that employers must ensure premiums are reasonable relative to the benefits provided. A lack of benchmarking can be framed as a breach of the duty of prudence.

5. Insurance product loss ratios — Loss ratios are being used as a proxy for value. Low ratios may be cited as evidence that plans were overpriced or structured to favor intermediaries rather than participants.

Steps employers can take

While none of these cases has been decided on the merits, they send the message that voluntary benefits are no longer viewed as litigation-proof. Employers and HR leaders may want to consider:

  • Confirming whether each voluntary benefit arrangement is intended to be ERISA-covered or exempt — and documenting that determination.
  • Reviewing contracts to clarify fiduciary roles, responsibilities and delegation.
  • Increasing transparency around broker and vendor compensation, including commissions and incentives.
  • Benchmarking premiums and insurer loss ratios against the broader market.
  • Documenting benefit selection decisions and the rationale behind them.
  • Strengthening employee decision support and education to demonstrate a focus on participant outcomes.

Voluntary benefits may remain optional for employees, but the lawsuits suggest fiduciary oversight is becoming less optional for employers. Employers that pay closer attention now to ensure compliance with any applicable fiduciary duties can reduce their risk of becoming the next test case.

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Uncategorized

Employers Experiment with Direct-to-Consumer Access for GLP-1s

Employers grappling with the cost and complexity of GLP-1 drugs are increasingly testing a workaround: steering certain employees to direct-to-consumer (DTC) arrangements that operate outside the company’s health plan.

The shift reflects a growing tension for benefits executives: how to manage soaring GLP-1 demand while preserving affordability, plan sustainability and clinical oversight.

How direct-to-consumer works

Under a DTC model, employees purchase GLP-1 drugs outside the pharmacy benefit on a manufacturer or designated website. Deductibles, out-of-pocket maximums, prior authorization and PBM utilization management requirements do not apply.

While this removes plan-level clinical guardrails, it can materially lower employees’ monthly costs. In many cases, cash-pay prices offered by manufacturers or online platforms are lower than what employees would pay through insurance even after discounts and coinsurance.

Instead of covering GLP-1s as a plan benefit, some employers provide fixed monthly stipends — often $100 to $200 — to offset the cost of direct purchases. This allows employers to cap financial exposure while still offering employees access to treatment.

Drug manufacturers are accelerating this shift. Eli Lilly and Novo Nordisk have expanded DTC programs that allow patients to purchase GLP-1 drugs without using insurance, with monthly cash prices below historical list prices.

Beyond consumer programs, both Lilly and Novo Nordisk are piloting direct-to-employer (DTE) models that bypass traditional PBM structures. In these arrangements, self-insured employers negotiate pricing directly with manufacturers, while third-party administrators handle eligibility screening, prescribing coordination and fulfillment. The goal is to move pricing closer to net cost and reduce employee cost-sharing.

According to the Peterson Health Technology Institute, some employers are evaluating DTC and DTE arrangements because these may offer lower prices than those through traditional pharmacy benefits. They also provide employers with more predictable spending. 

However, benefits leaders should view these arrangements as complementary tools rather than replacements for a structured GLP-1 strategy.

Pros and cons

Pros:

  • Lower out-of-pocket costs for certain employees.
  • Second-chance access for employees who do not qualify under plan rules.
  • Predictable employer cost exposure when using fixed stipends or subsidies.
  • DTC models typically bypass prior authorization and PBM requirements, reducing friction and administrative delays for employees.

Cons:

  • Loss of clinical oversight and utilization controls. Off-benefit purchases bypass prior authorization, step therapy and ongoing clinical management built into the plan.
  • Employers lose access to claims data needed to track adherence, safety, effectiveness and long-term cost trends.
  • Employees may underestimate their total financial exposure, particularly if they later transition back to plan-based coverage.
  • Cash-pay prices can make plan coverage appear inefficient or overpriced, even when the pricing structures are not directly comparable.
  • Manufacturer DTC pricing reflects market strategy, not negotiated benefit contracts, and can change or be withdrawn with little notice.
  • Once established for GLP-1s, employees may expect similar pathways for other high-cost medications.

What employers can do

For many employers, the most pragmatic use of DTC access is as a secondary pathway. Employees who do not meet plan eligibility criteria can still pursue treatment without forcing employers to broaden coverage in ways that may be financially unsustainable.

As manufacturers continue to refine pricing strategies and employer pilots mature, benefits executives may find that selective use of DTC models offers flexibility in an increasingly complex GLP-1 landscape — provided these pathways are integrated thoughtfully into an overall benefits strategy rather than used as a blunt cost-cutting tool.

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Uncategorized

Model Law Could Spur States to Rein in Prior Authorization

A new model law adopted by the executive committee of the National Council of Insurance Legislators (NCOIL) could spur more states to adopt legislation to regulate health insurers’ use of prior authorization.

While prior authorization remains an important tool for managing utilization and costs, insurers’ rules are often opaque, which leads to confusion and frustration among patients who have been denied or experienced delayed care. As a result, lawmakers in many states are looking for guardrails that improve transparency and predictability without dismantling the process altogether.

NCOIL’s model act draws heavily from reforms enacted in Mississippi and influenced by similar efforts in Minnesota. The organization does not regulate insurance itself, but its model laws often serve as starting points for state legislation, particularly on complex insurance issues.

What the model act does

If adopted by states, the model law would establish several baseline requirements for health insurers and health plans, including:

  • Publicly posting a complete list of services subject to prior authorization, along with applicable requirements and clinical review criteria.
  • Publishing prior authorization approval and denial statistics in an accessible format.
  • Completing expedited prior authorization reviews within 24 hours after all necessary information is received.
  • Ensuring that appeals are reviewed by physicians with appropriate training or experience relevant to the service under review.
  • Reporting aggregated annual data on prior authorization activity to state insurance regulators.

These steps are designed to reduce administrative friction and make the process more predictable for providers and patients, while still allowing insurers to manage care.

The model preserves insurers’ ability to require prior authorization for certain services — such as advanced imaging or surgical procedures — while setting clearer expectations for how those programs operate. This is important for employers since prior authorization can help rein in unnecessary spending, while unpredictable delays can disrupt employees’ care and productivity.

Minnesota’s experience

NCOIL leaders have pointed to Minnesota as an example of how structured prior authorization rules can work in practice. Reforms there emphasized transparency, timeliness and accountability, and are widely viewed by policymakers as having improved the process without driving up costs or undermining insurers’ role in utilization management.

That track record gives the model act additional credibility as states consider whether and how to intervene. For employers operating in multiple states, it also raises the prospect of more consistent rules across jurisdictions over time, rather than a patchwork of sharply different requirements.

What employers should watch

For now, the model act does not change any existing laws. Each state would need to introduce and pass its own legislation, and lawmakers may adopt the model in full or only in part. Still, prior authorization has become a bipartisan priority at the state level, particularly as concerns grow about access to care and administrative burden.

Employers that purchase fully insured health plans should pay attention to legislative activity in the states where they operate, as new requirements could affect plan administration, reporting and vendor relationships. Even employers with self-funded plans may see indirect effects as insurers and third-party administrators adjust processes to align with emerging state standards.

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Uncategorized

‘Stealth’ Health Plan Cost Drivers Employers Can’t Ignore

As employers face rapidly rising health insurance costs for their employees, industry pundits are increasingly urging benefit leaders to confront “stealth” cost drivers that quietly inflate spending year after year.

While headline issues like premium increases draw the most attention, some of the most meaningful opportunities to control costs lie in areas that are often underinvested or poorly integrated into benefit strategies.

Addiction support services

Behavioral health, and particularly substance use disorders, remains one of the most expensive and least efficiently managed areas of employer-sponsored health care.

Untreated mental health and addiction issues contribute to higher medical claims, absenteeism and lost productivity. According to the Center for Prevention and Health Services, untreated mental health concerns can cost a single organization tens of thousands of dollars annually and amount to more than $100 billion nationwide.

Despite those figures, addiction and recovery services have historically received less attention than other wellness initiatives. Inpatient treatment models can be disruptive for employees and expensive for employers, while high relapse rates have made some organizations hesitant to invest more heavily in this space.

Employer actions: As a result, employers are increasingly looking at more structured, accountable recovery programs that focus on ongoing support, medication-assisted treatment and measurable outcomes.

Improving access to specialty care

Employees may technically have coverage, but long wait times for specialists can delay treatment and worsen underlying conditions. Nationally, more than 100 million specialty referrals are issued each year, yet patients in many metropolitan areas wait more than a month to see specialists such as gastroenterologists, dermatologists or cardiologists.

When employees cannot access specialty care in a timely manner, they are more likely to rely on emergency rooms or urgent care, which drives up costs.

Employer actions: Some employers are responding by supplementing traditional plans with specialty telehealth solutions or third-party platforms that shorten wait times and improve care coordination.

Consider surveying employees to identify gaps in access and understand whether additional solutions are warranted.

Accessing plan analytics to tailor benefits

Because many organizations still design benefits based on assumptions rather than real utilization patterns, only a small share of workers report being truly satisfied with their benefits — suggesting a disconnect between what is offered and what is needed.

Employer actions: Use carrier-provided tools, if available, such as reporting dashboards, health risk assessments or plan modeling software. Review claims data at least quarterly to identify cost trends, any under- or overutilization, emerging risks or cost anomalies.

Understanding which programs are being used, where employees are falling through the cracks and which interventions are producing results allows organizations to refine benefits with greater precision and financial discipline.

The takeaway

Rising health care costs are unlikely to ease in the near term, but employers are not without options. While there are many areas that can be addressed, focusing on emerging cost-containment efforts could be a winning strategy for employers.

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Uncategorized

Seven Tips for Avoiding High Medical Bills

When people sign up for a new health insurance plan, be that an employer-sponsored plan or one purchased on the Affordable Care Act (ACA) exchange, they can often be confused about when coverage starts, what is covered and whether they have to share in the medical bills.

The Kaiser Family Foundation recently compiled a list of seven takeaways from stories about people who ended up paying large out-of-pocket expenses for medical care. Health plan enrollees should read the following to learn how they can better use their plan and avoid financial blowback.

1. Most insurance coverage doesn’t start immediately

Many new plans come with waiting periods, so it’s important to maintain continuous coverage until a new plan kicks in.

One exception: An employee can opt into a COBRA policy or purchase a plan on the ACA marketplace (healthcare.gov or a state-run plan in certain states) within 60 days of losing their job-based coverage. With COBRA, once you pay, the coverage applies retroactively, even for care received while you were temporarily uninsured.

They will also qualify for a special enrollment period on the ACA marketplace to get coverage for the rest of the year. Coverage can start the first day of the month after someone loses their employer-sponsored coverage.

2. Check coverage before checking in

Some plans come with unexpected restrictions, potentially affecting coverage for care ranging from contraception to immunizations and cancer screenings.

Enrollees should call their insurer — or, for job-based insurance, their human resources department or retiree benefits office — and ask whether there are exclusions for the care they need, including per-day or per-policy-period caps, and what they can expect to pay out-of-pocket.

3. ‘Covered’ does not mean insurance will pay

Carefully read the fine print on network gap exceptions, prior authorizations and other insurance approvals. The terms may be limited to certain doctors, services and dates.

Also, while the service may be covered, sometimes it won’t be until the deductible or out-of-pocket maximum is met.

4. Get estimates for nonemergency procedures

Before scheduling a nonemergency procedure, an enrollee may be able to shop around among different providers that offer the procedure. Request estimates in writing and if an enrollee objects to the price, they should negotiate before undergoing care.

5. Location matters

Prices can vary depending on where a patient receives care and where tests are performed. If a patient needs blood work, they should ask their doctor to send the requisition to an in-network lab.

A doctor’s office connected to a health system, for instance, may send samples to a hospital lab, which can mean higher charges if it’s not in-network.

6. When admitted, contact the billing office early

When an enrollee or a loved one has been hospitalized, it can help to speak to a billing representative if possible. Questions to ask:

  • Has the patient been fully admitted or are they being kept under observation status?
  • Has the care been determined to be “medically necessary?”
  • If a transfer to another facility is recommended, is the ambulance service in-network or is it possible to choose one that is?

7. Ask for a discount

Medical charges are almost always higher than what insurers would pay, and providers expect them to negotiate lower rates. Health plan enrollees can also negotiate.

Uninsured or underinsured patients may be eligible for self-pay or charity care discounts.

"ACA"/
Uncategorized

Get ACA Reporting Right and Avoid Fines

Applicable large employers face a familiar but unforgiving task each winter: reporting their group health coverage details to the IRS. With key ACA Affordable Care Act filing deadlines falling in early 2026, employers with 50 or more full-time equivalent employees should already be reviewing records, reconciling data and preparing required forms to avoid penalties.

ACA reporting is largely about accuracy and timing, and problems often stem from waiting too long to pull information together. Here’s how to get it right and avoid penalties. 

Who must report and why

An applicable large employer, or ALE, is generally an employer that averaged at least 50 full-time employees, including full-time equivalents, during the prior calendar year. Employers that met that threshold in 2025 must comply with ACA employer shared responsibility reporting in 2026.

ALEs must report whether they offered minimum essential coverage to full-time employees and whether that coverage met affordability and minimum value standards. The IRS uses this information to determine whether an employer must pay a penalty for failing to meet these requirements and to verify employees’ eligibility for premium tax credits if they purchase their own health insurance on the ACA marketplace.

The required forms

ACA reporting for ALEs revolves around two forms:

1. Form 1095-C — This form must be furnished to each full-time employee, regardless of whether the employee enrolled in coverage. The form reports the health coverage offered, if any, for each month of the year.

2. Form 1094-C — This form is filed with the IRS and serves as a summary transmittal of all 1095-C forms. Form 1094-C aggregates employer-level data, including employee counts and whether the employer is part of an aggregated group.

Due date: Employers must file paper Forms 1094-C and 1095-C with the IRS on or before March 2 for firms eligible to file on paper and electronically on or before March 31, and no additional extensions are available. Employers that file a combined total of 10 or more information returns must file electronically.

Prepare

The most common ACA reporting issues trace back to incomplete or inconsistent data. Employers can reduce risk by preparing well in advance:

  • Confirm 2025 full-time and full-time equivalent counts to ensure ALE status was correctly determined.
  • Review payroll, time-tracking and benefits systems to ensure hours worked, eligibility and coverage offers align.
  • Verify employee names and Social Security numbers.
  • Confirm monthly employee contributions for the lowest-cost, self-only plan that provides minimum value.
  • Review affordability calculations using the 2026 affordability threshold of 9.96%.

Be aware that hybrid and remote work arrangements can complicate efforts to track employee hours and determine eligibility. Make sure your system accurately captures hours worked regardless of the employee’s location.

Potential penalties for noncompliance

Late, incomplete or incorrect filings can trigger penalties under Internal Revenue Code Sections 6721 and 6722 for failure to file correct information returns and failure to furnish correct payee statements. Penalties generally apply per form and can add up quickly.

Separately, inaccurate reporting can expose employers to employer shared responsibility assessments if at least one full-time employee receives a premium tax credit through a marketplace. For 2026:

  • The penalty is $3,340 per full-time employee, excluding the first 30 employees, if coverage was not offered to at least 95% of full-time employees and dependents.
  • The penalty is $5,010 per affected employee if coverage was offered but was unaffordable or failed to meet minimum value, and the employee received a premium tax credit.

Bottom line

ACA reporting is not just a new year task. Employers that reconcile data throughout the year, confirm affordability calculations and review forms before deadlines are far less likely to face penalties or IRS follow-up.

Preparation should be well underway in January. Waiting until February often leaves too little time to fix errors before the March filing deadlines arrive.

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Uncategorized

ACA Subsidy Expiration Could Ripple Through Group Health Plans

The expiration of enhanced premium subsidies that have helped millions of Americans afford individual health insurance through the Affordable Care Act exchanges at the end of 2025 will be felt by employers offering group health plans.

As exchange coverage becomes less affordable for many households, more workers may look to employer-sponsored plans for stability, while employers that fund Individual Coverage Health Reimbursement Arrangements (ICHRA) to help employees buy coverage may need to revisit affordability and contribution strategies because the same employer funds may cover a smaller share of premiums than before when purchasing health insurance on Healthcare.gov and other state-run exchanges.

The temporary subsidy enhancements enacted during the COVID-19 pandemic removed the 400% federal poverty level income cap and increased the value of premium tax credits across income brackets. As a result, subsidized exchange enrollment nearly doubled between 2020 and 2024. If the enhanced subsidies expire, higher-income households will lose eligibility altogether while those who remain eligible will receive smaller credits and pay more for their share of the premium.

Increasing enrollment pressure

For employers offering traditional group health coverage, one likely consequence is increased enrollment pressure. As individual premiums rise, employees who previously declined employer coverage may opt in during open enrollment.

That could affect plan participation, contribution levels and claims experience particularly if workers with higher health care needs are more motivated to seek employer coverage.

Labor dynamics could also shift. Workers without access to affordable employer-sponsored coverage may be more inclined to change jobs to secure benefits, potentially influencing recruitment and retention in competitive labor markets. At the same time, fewer employees qualifying for exchange subsidies could slightly reduce applicable large employers’ exposure to costly ACA “pay or play” penalties, which are triggered when full-time employees receive premium tax credits.

ICHRA effects

The impact may be more immediate for employers offering ICHRAs, which reimburse employees for individual market coverage rather than providing a group plan.

If subsidies shrink and marketplace premiums rise, some ICHRA allowances that were previously affordable may no longer meet regulatory affordability thresholds. Employers may need to increase contribution levels or adjust benchmark assumptions to remain compliant.

Industry experts have also warned that abrupt shifts in individual market enrollment could create volatility. A contraction in exchange enrollment — particularly if healthier individuals drop coverage — could put upward pressure on premiums, further complicating affordability for both employees and employers relying on individual-market plans.

At the same time, the uncertainty may accelerate interest in alternative benefit strategies. Employers facing steep group plan renewals may explore ICHRAs to shift risk to the broader individual market, though that strategy becomes more complex if exchange affordability deteriorates.

What employers should consider now

Now that the enhanced subsidies have expired, employers may want to:

  • Review group health plan affordability and employee contribution structures.
  • Reassess ICHRA allowance levels and benchmark plans if applicable.
  • Evaluate workforce demographics and possible enrollment shifts for 2026.
  • Prepare employee communications that explain coverage options and tradeoffs.
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