Within a one-week period, there were two actions at the federal level to increase pharmacy benefits manager (PBM) transparency. The Consolidated Appropriations Act of 2026 (CAA 2026) and Department of Labor (DOL) proposed...more
On January 30, 2026, the Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) published proposed regulations (408(b) rules) that would significantly increase transparency requirements for pharmacy...more
On December 9, 2025, the Internal Revenue Service (IRS) provided clarifying guidance in Notice 2026-5 (the Notice) regarding several account-based health plan provisions contained in the One Big Beautiful Bill Act (OBBBA)....more
The Departments of the Treasury, Internal Revenue Service (IRS), Health and Human Services (HHS) and Labor (DOL) (together, the Departments) published proposed rules on December 23, 2025 (Proposed Rule), aimed at improving...more
The Department of Health and Human Services (HHS) published a proposed rule on November 28, 2025 (the Proposed Rule) that would carve out account-based group health plans from the requirement to provide a Medicare Part...more
For over a decade, Applicable large employers (ALEs), those with 50 or more full-time equivalent employees, have been required to annually report health insurance coverage information to the IRS and to employees on Form...more