Skip to content
BRCC / Baldwin Bulletin – January 2026

COMPLIANCE NEWSLETTER – JANUARY 2026

Baldwin Bulletin

BALDWIN REGULATORY COMPLIANCE COLLABORATIVE

Welcome to the January 2026 issue

The Baldwin Bulletin is a compliance newsletter authored by the Baldwin Regulatory Compliance Collaborative and 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.

This month’s issue focuses on important upcoming compliance deadlines and includes our timeline of upcoming compliance requirements, in addition to providing information regarding certain hot-button compliance issues significantly impacting employers

Upcoming Compliance Deadlines

For information regarding upcoming compliance deadlines for employer-sponsored group health plans.
Read more

2025 compliance year in review

Several key regulatory changes took effect in 2025 under the One Big Beautiful Bill Act (“OBBBA”), alongside meaningful shifts in federal enforcement priorities.
Read more

2025 ACA reporting forms and deadlines

The IRS has released the final 2025 ACA reporting forms and instructions, including new guidance on an alternative method for furnishing Forms 1095-C through a public website notice.
Read more

CMS Medicare Part D reporting deadline

Employers offering prescription drug coverage must report creditable or non-creditable coverage status to CMS within 60 days of the plan year start and following certain plan changes.
Read more

IRS FAQ addresses OBBBA flexibilities for HSA-compatible telehealth and direct primary care

The IRS issued Notice 2026-5, clarifying how HSA-compatible HDHPs may offer telehealth services below the deductible under OBBBA’s permanent safe harbor.
Read more

State individual mandates: What employers need to know about state reporting and penalties

Several states continue to enforce individual health insurance mandates with separate employer reporting obligations.
Read more

HIPAA Notice of Privacy Practices update deadline

Self-funded group health plans must update their HIPAA Notice of Privacy Practices by February 16, 2026, to reflect new federal requirements related to substance use disorder records.
Read more

Voluntary benefit plans facing new wave of ERISA fiduciary suits

Recent lawsuits have challenged employers and advisors over alleged ERISA fiduciary breaches tied to voluntary benefits such as hospital indemnity and accident plans.
Read more

California Corner: Self-funded plan San Francisco HCSO top-off payments due soon

Employers with self-funded plans must evaluate annual health care spending under San Francisco’s HCSO and make any required top-off payments by February 28.
Read more

California corner: Reminder regarding California’s individual mandate Franchise Tax Board filing

California’s individual mandate creates separate reporting and furnishing requirements for employers sponsoring self-funded plans covering California residents.
Read more

California corner: Understanding imputed income for California registered domestic partners

Federal tax rules generally require imputed income for domestic partner coverage, but California provides favorable tax treatment for registered domestic partners and their children.
Read more

Frequently Asked Question (“FAQ”) of the Month

This month’s FAQ explains how benefit eligibility is affected when an employee moves from full-time to part-time status and outlines best practices for monitoring variable hours after the transition.
Read more

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

2026 HIPAA Complete Training Calendar

View insight

2026 Baldwin Professional Education Connection Educational Webcast Calendar

View insight

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.

Get in touch with our compliance team

The Baldwin Regulatory Compliance Collaborative is a national team of compliance and ERISA experts to help keep your organization compliant and informed.

Connect with us