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… breached fiduciary duties by allowing excessive prescription drug pricing in its health plan. The court found plaintiffs lacked Article III standing because they failed to demonstrate a concrete financial injury. Conversely, Stern v. JPMorgan Chase will move forward after a court allowed claims alleging fiduciaries failed to prudently monitor PBM arrangements and allowed participants to pay inflated prices for generic drugs. These cases reinforce the importance for plan fiduciaries to maintain strong governance, actively monitor vendors, and document efforts to meet ERISA’s duties of prudence and loyalty. All-Payer Claims Databases Employers may be receiving letters from their third …

… that pose the greatest risk to plan participants and beneficiaries. Specific to health and welfare benefit plans, investigations will prioritize cybersecurity, access to mental health and substance use disorder benefits, surprise medical billing, and handling of employee contributions. EBSA also signaled a continued commitment to addressing abusive Multiple Employer Welfare Arrangements (MEWAs). US Department of Labor’s Employee Benefits Security Administration updates national enforcement projects for employee benefit plans | U.S. Department of Labor DOL Announces Delinquent Filer Program for MEWAs In a notice published in the Federal Register on December 31, 2025, the Department of Labor (DOL) announced that …

… disclosures of protected health information (PHI), and gives individuals certain rights, including the right to timely access to health records and the right to obtain a copy of their health records. The updated HIPAA FAQs address how covered health care providers are permitted to disclose PHI to value-based care arrangements for treatment purposes, and what health information is included in a designated record set and thus subject to the individual’s right to access such information New and Updated FAQs: New. Does the HIPAA Privacy Rule permit a covered health care provider to disclose protected health information to value …

… Affordable Care Act (ACA) Patient-Centered Outcomes Research Institute (PCORI) fees no later than July 31, 2025. Fully insured plan sponsors can rely on their carriers to submit the fee on their behalf, but fully insured plan sponsors that sponsor a self-funded plan component, such as a health reimbursement arrangement (HRA), will need to file and pay for the self-funded component plan. Payment amounts due in 2025 will differ based on the employer’s plan year. The Internal Revenue Service (IRS) provides a chart showing applicable fee amounts depending on the plan’s year-end date. The fees …