This past quarter brought another wave of regulatory shifts, agency guidance, and court decisions shaping the compliance landscape for employer-sponsored health and welfare plans. From Medicare Part D creditable coverage notices and draft ACA reporting instructions to new enforcement actions around mental health parity and provider directories, Q3 underscored the need for careful compliance planning as renewal season approaches.

The massive budget reconciliation bill known as the One Big Beautiful Bill Act (OBBBA) was signed into law by President Trump on July 4, 2025. As with many such budget bills, there were various employee benefits provisions tucked into its depths, including changes for health savings accounts (HSAs), dependent care assistance programs (DCAPs), student loan payments under educational assistance programs, and qualified transportation plans.

As renewal season approaches, employers should take a proactive approach to reviewing their health and welfare benefit offerings. This is the ideal time to align plan design, documentation, and administration with federal and state requirements, while also confirming that carriers and vendors are prepared to support the upcoming plan year. Careful planning reduces compliance risk, ensures employee communications are accurate, and helps avoid costly corrections later. 

Employers are not required to offer creditable prescription drug coverage, but they are required to determine and communicate creditable (or non-creditable) status to eligible individuals. This information assists Medicare Part D eligible individuals in making informed decisions about enrolling in Medicare Part D and helps avoid late enrollment penalties. 

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