On November 13, 2025, the Internal Revenue Service (IRS) released Notice 2025-67, which sets forth the 2026 cost-of-living adjustments affecting dollar limits on benefits and contributions for qualified retirement plans. The IRS also announced the health savings account (HSA) and high deductible health plan (HDHP) annual deductible and out-of-pocket expense adjustments earlier this year
Understanding Employee Benefits and key developments in the employee benefits field and items of interest to our clients. MORE
Cafeteria Plans
HSA/HDHP Limits for 2026
On May 1, 2025, the Internal Revenue Service (IRS) released Revenue Procedure 2025-19, which provides the 2026 inflation adjusted limits related to Health Savings Accounts (HSAs) and High Deductible Health Plans (HDHPs).
The following charts summarize the 2026 limits for HSAs and HDHPs. The 2025 limits are provided for reference.
| Annual HSA Contribution Limit |
DOL’s ARPA COBRA Subsidy Notices and FAQs: Stay Tuned for More
On March 11, 2021, President Biden signed the American Rescue Plan Act of 2021 (“ARPA”) into law. Under ARPA, certain employees and their dependents who lost group health coverage during the COVID-19 pandemic due to the employee’s involuntary termination (other than for gross misconduct) or reduction of hours are allowed to temporarily receive fully-subsidized COBRA…
IRS Guidance on Coronavirus Relief for FSAs, DCAPs, and Cafeteria Plans: Almost Anything Goes
On February 18, 2021, the IRS issued Notice 2021-15, clarifying temporary special rules for cafeteria plans, health flexible spending accounts (“FSAs”), and dependent care assistance programs (“DCAPs”) that were included in the Consolidated Appropriations Act (“CAA”), enacted on December 27, 2020. The Notice also adds temporary opportunities to make changes in health plan coverage under…
Same Sex Marriage: Effect on Benefits
The United States Supreme Court recently held in Obergefell v. Hodges http://www.supremecourt.gov/opinions/14pdf/14-556_3204.pdf that all states must recognize and allow marriages between same sex partners. Depending on an employer’s current employee benefits plan, certain provisions may need to be changed in light of this ruling.
For those employers who already provide spousal benefits to same sex…
Gas Prices Must be Going Down
Every year the IRS issues optional standard mileage rates that can be used by taxpayers to calculate the deductible cost of operating an automobile for business, charitable, medical or moving purposes. Many employers reimburse employees based on this standard mileage rate. The standard mileage rate also factors into medical expense reimbursement account plans for mileage …
IRS Loosens Use It or Lose It Rule
As employers who sponsor cafeteria plans know, flexible spending accounts (FSAs) under those plans have had a “use it or lose it” rule. Under that rule, employees who participate in the spending accounts must make elections at the beginning of the year to set aside amounts to pay medical expenses under a medical FSA or …
No More Pre-Tax Premiums for Individual Insurance Policies?
Over the years we have seen some employers, particularly small employers, choose to provide health coverage to their employees by paying all or part of the premium for individual insurance policies that the employees have obtained. Under an old IRS revenue ruling, Rev. Rul. 61-146, that type of premium subsidy could be provided on a …
New Requirements for BAAs
As many employers know, HIPAA rules require them to sign on behalf of their health plans Business Associate Agreements (BAAs) with the vendors who assist in plan administration. Many employers also know that earlier this year, the U.S. Department of Health and Human Services issued final regulations which will require updated BAAs by September 23, …
Effect on Employers of Same Sex Marriage in Minnesota
As many of our readers know, on Tuesday, May 14, 2013, Minnesota became the twelfth state to recognize same sex marriages. The effective date of the change is August 1, 2013, which gives employers some time to react to the change and analyze its effect on their employment policies and benefits. We sent an Alert …