Coverage made HUMAN.

IRS enforcement on ACA reporting is accelerating in 2026. If your 2023 filings had errors, a Letter 226J may already be on its way. If your 2024 filings aren't clean, expect to hear about it before year-end. Penalties run $3,340 to $5,010 per employee, per year. Add a new affordability threshold of 9.96% for 2026, and your contribution strategy may need a fresh look. Don't wait for a letter to find out you have a problem.

Federal regulators have made mental health parity a top enforcement priority this year. Under the CAA, your plan must have written, data-supported documentation proving your mental health benefits are truly comparable to your medical benefits — in how the rules are actually applied, not just on paper. Most small-to-mid-size employers don't have this on file. If you haven't had an NQTL review done, you may be exposed.

Under the Consolidated Appropriations Act, every group health plan must file an annual attestation confirming it has no "gag clauses" — provisions that block employees from seeing cost or quality data on their own coverage. The 2026 deadline hits at year-end. If you haven't confirmed whether your carrier or TPA filed this on your behalf, the answer is probably no — and the obligation sits with you as the plan sponsor.

The IRS raised the out-of-pocket maximum for self-only coverage to $9,200 in 2026 — and family coverage follows. Employees on HDHPs are carrying more financial risk than ever, and most don't realize it until they get a bill. This is a good time to revisit plan design: adjusting your HSA contribution, adding a supplemental product, or exploring a level-funded structure that gives you more control over what your people actually pay.