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
Health Plan
Federal Court Strikes Down HIPAA Reproductive Health Privacy Rule – What it Means for Health Plan Compliance
By: Lisa Rippey and Elena Humphrey
In a landmark decision, a federal district court in Texas struck down nearly all of the 2024 amendments to the HIPAA Privacy Rule, known as the Reproductive Health Privacy Rule (the “Rule”), ruling that the Department of Health and Human Services (“HHS”) exceeded its statutory authority. The ruling, which…
Federal Agencies Hit Pause on MHPAEA 2024 Final Rule Enforcement
On May 15, 2025, the Departments of Labor, Health and Human Services, and Treasury (the “Departments”) issued a statement of non-enforcement (the “Statement”) announcing that they will not enforce the 2024 Final Rule under the Mental Health Parity and Addiction Equity Act (“MHPAEA”).
The MHPAEA requires group health plans to provide mental health and substance…
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 Settlements Remind Employers to Avoid Collecting Premiums Until Evidence of Insurability is Approved
The U.S. Department of Labor (DOL) announced two settlements with major insurance companies this month that highlight the importance of employers avoiding the collection of group life insurance premiums from employees until the insurer has approved them for coverage, including receipt and approval of required evidence of insurability (EOI). These settlements follow two similar agreements…
Temporary Extension of CARES Act Telehealth/HSA Relief Available
On March 15, 2022, the Consolidated Appropriations Act of 2022 (“2022 CAA”) was signed into law. Among other things, the 2022 CAA temporarily restores the telehealth relief provided under the CARES Act. The CARES Act permitted high deductible health plans (“HDHP”) to provide telehealth services or other remote care services without applying a deductible. This…
Agencies Issue Additional Guidance Regarding Over-the-Counter COVID-19 Test Coverage
As indicated in our January 11, 2022 blog post and alert, the Department of Labor, the Department of Health and Human Services, and the Treasury (the “Agencies”) issued FAQs Part 51 on January 10, 2022, requiring group health plans to cover over-the-counter (“OTC”) COVID-19 tests without participant cost-sharing, preauthorization, or medical management. In response…
Agencies Issue Guidance Requiring Coverage for Over-the-Counter COVID-19 Tests
Beginning January 15, 2022, and through the duration of the public health emergency, insurers and group health plans must cover at-home COVID-19 diagnostic tests available over-the-counter (OTC) without imposing cost-sharing, prior authorization, or other medical management requirements. This requirement stems from the latest guidance issued on January 10, 2022, by the Department of Health and…
Agencies Issue COVID-19 Vaccine Incentive Guidance
On October 4, 2021, the Department of Health and Human Services, Department of Labor and Treasury jointly issued FAQs relating to COVID-19 vaccine incentives and surcharges. Under the guidance, employers may provide incentives such as premium discounts or surcharges through group health plans to incentivize COVID-19 vaccines, provided the incentive complies with the activity-only…
IRS Releases Guidance on Premium Subsidies for Continuation Coverage under COBRA
On May 18, 2021, the Internal Revenue Service (IRS) released much-anticipated guidance on premium subsidies for continuation coverage under Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) provided by the American Rescue Plan Act of 2021 (ARPA). For more information about the ARPA and COBRA subsidies, see Stinson’s previous blog: American Rescue Plan Act Contains…