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… 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 …

… Retirement Income Security Act (ERISA) to designate pharmacy benefit managers (PBMs) as fiduciaries when they provide services to employer-sponsored health plans. Under the proposal, PBMs would be legally required to act in the best interests of plan sponsors and participants, similar to how ERISA already treats other service providers. Additionally, PBMs would be required to disclose their compensation, including direct and indirect fees, rebates, discounts, and price concessions. Proponents argue that this increased transparency and fiduciary accountability will help employers better assess whether PBM arrangements are reasonable and aligned with plan cost-management goals. This, in turn, would address

… national standards to protect individually identifiable health information, sets limits and conditions on the uses and 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

… 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 due in July 2025 are as follows: $3.22 per covered life for plan years ending after September 30, 2023, and …