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BRCC / Baldwin Bulletin – August 2025

COMPLIANCE NEWSLETTER – August 2025

Baldwin Bulletin

BALDWIN REGULATORY COMPLIANCE COLLABORATIVE

Welcome to the August 2025 issue

The Baldwin Bulletin serves as a monthly guide to important regulatory developments, legal news, and employee benefits-related industry happenings designed to keep you abreast of the latest developments.

Highlights include the 2026 ACA employer penalty increases, ERISA implications for state “mini-COBRA,” Medicare Part D creditable coverage changes, new Marketplace cost-sharing limits, and recent court rulings on the PWFA and HIPAA reproductive health protections. We also review major California developments and launch our ACA in M&A white paper series.

Upcoming Compliance Deadlines

For information regarding upcoming compliance deadlines for employer-sponsored group health plans.
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IRS Announces 2026 Affordable Care Act Pay-or-Play Penalties

On July 22, 2025, the IRS announced increased penalty amounts for 2026 under the ACA’s employer shared responsibility rules, raising the adjusted $2,000 and $3,000 penalties to $3,340 and $5,010, respectively.
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Navigating “Mini-COBRA” or “COBRA-like” Requirements: A New Era for ERISA Compliance

A recent court ruling clarifies that state-level health care continuation coverage—often referred to as “mini-COBRA”—is subject to ERISA’s fiduciary duties.
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Navigating Medicare Part D: 2026 Creditable Coverage Changes & Disclosure Essentials for Employers

As employer-sponsored health plans prepare for 2026, the Inflation Reduction Act has reshaped Medicare Part D benefits, prompting changes to how employers assess creditable coverage.
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HHS Issues Final Rule on Marketplace Integrity and Affordability Including Annual Maximum Out-of-Pocket Limits

On June 20, 2025, the U.S. Department of Health and Human Services issued a Final Rule under the ACA that sets the 2026 maximum annual cost-sharing limits at $10,600 for self-only coverage and $21,200 for other coverage.
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Pregnant Workers Fairness Act Abortion Accommodations Mandate has been Vacated

The Pregnant Workers Fairness Act mandates that employers provide reasonable accommodations for pregnancy-related conditions unless doing so causes undue hardship.
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HIPAA Privacy Final Rule to Support Reproductive Health Care Privacy Vacated

The U.S. District Court for the Northern District of Texas, on June 18, 2025, vacated most provisions of the 2024 HIPAA Final Rule intended to strengthen reproductive health care privacy,
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California Corner: California State Insurance Code Mandate Requiring Coverage of IVF Delayed

California’s SB 729 mandates that large group insured health plans (100+ employees) cover up to three IVF-related oocyte retrieval cycles, with implementation now delayed from July 1, 2025,
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California Corner: Reminder Regarding Increased Regulation of Insured Dental Plans

During the 2023/2024 legislative cycle, California enacted AB 1048 and AB 952 to strengthen consumer protections in insured dental plans. AB 1048 prohibits large group dental plans from
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California Corner: 2026 San Francisco Health Care Security Ordinance Expenditures

The San Francisco Office of Labor Standards Enforcement has released updated 2026 health care expenditure rates under the Health Care Security Ordinance, increasing the hourly rates
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The ACA In Mergers in Acquisitions – Part I

This first article of a three-part series examines potential liabilities arising during a Merger, Acquisition, or Spin-off as it relates to ACA mandated reporting for Applicable Large Employers
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Frequently Asked Question (“FAQ”) of the Month

Our FAQ of the Month focuses on understanding individual coverage health reimbursement arrangements (“ICHRAs”).
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FEATURED COMPLIANCE INSIGHTS

Training and webcast calendars

Stay on top of everything and never miss out with our comprehensive calendars guiding you every step of the way

2025 HIPAA Complete Training Calendar

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2025 Baldwin Professional Education Connection Educational Webcast Calendar

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This newsletter is intended for general information purposes only and should not be construed as advice or opinions on any specific facts or circumstances. The content of this newsletter is made available on an “as is” basis, without warranty of any kind. The Baldwin Insurance Group Holdings, LLC (“The Baldwin Group”), its affiliates, and subsidiaries do not guarantee that this information is, or can be relied on for, compliance with any law or regulation, assurance against preventable losses, or freedom from legal liability. This publication is not intended to be legal, underwriting, or any other type of professional advice. The Baldwin Group does not guarantee any particular outcome and makes no commitment to update any information herein or remove any items that are no longer accurate or complete. Furthermore, The Baldwin Group does not assume any liability to any person or organization for loss or damage caused by or resulting from any reliance placed on that content. Persons requiring advice should always consult an independent adviser.

The Baldwin Group offers insurance services through one or more of its insurance licensed entities. Each of the entities may be known by one or more of the logos displayed; all insurance commerce is only conducted through The Baldwin Group insurance licensed entities. This material is not an offer to sell insurance.

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