As legal and regulatory developments continue to reshape the group health plan landscape, employers need to be vigilant. In 2024 and 2025, several new and revised federal model notices were released to help organizations comply with federal disclosure requirements. At the same time, key court rulings and legislative changes have temporarily suspended or eliminated certain obligations.
Employers are not required to use federal model notices, but if they choose to create or modify their own versions, they must still meet the minimum disclosure standards. Ensuring your materials are both current and compliant is critical.
Here is what you need to know.
Updated and New Federal Model Notices
Several federal notices have been updated or newly released to reflect legal and policy changes.
Employer CHIP Notice
Employers with group health plans covering individuals in states that offer premium assistance under Medicaid or CHIP must provide an annual notice. The updated model notice reflects information current as of July 31, 2025, and is available in both English and Spanish.
Educational Assistance Programs
The IRS released a sample plan document in 2024 for employers offering educational assistance programs under Section 127 of the Internal Revenue Code. This allows employers to offer up to $5,250 annually in tax-free educational assistance, now including student loan repayment benefits. This provision, originally set to expire, was permanently extended by legislation enacted on July 4, 2025.
Health Insurance Exchange Notices
The ACA requires employers to inform new hires about the health insurance Exchanges. Model notices were updated in early 2024 to reflect changes related to affordability thresholds, special enrollment periods, Medicaid and CHIP eligibility, and optional employer coverage tools. Versions are available for employers who do and do not offer group health plans.
Legal and Legislative Developments Impacting Notices
Recent developments have reduced or delayed certain notice requirements. Employers should adjust their compliance strategies accordingly.
ACA Simplified Reporting Requirements
Beginning in 2025, new federal laws reduce ACA reporting burdens. Applicable large employers are no longer required to furnish Forms 1095-C unless an employee requests a copy. However, employers must post a clear and accessible notice on their website informing individuals of this option. Forms must be provided within 30 days of the request or by January 31 of the following year, whichever is later. Employers may also now use an individual’s date of birth in place of a taxpayer identification number in certain cases and can electronically deliver statements with prior consent.
Fixed Indemnity Coverage Notice Requirement Removed
A 2024 final rule introduced a notice requirement for fixed indemnity coverage, a type of limited benefit insurance. That requirement was struck down by a federal court in December 2024. The Biden-era executive order supporting the notice was also rescinded in early 2025. Fixed indemnity coverage can still be offered, but employers should monitor for further changes.
Section 1557 Nondiscrimination Notices
New requirements under ACA Section 1557, including notices about nondiscrimination and language assistance services, were scheduled to take effect in 2024 and 2025. These are now subject to multiple federal court injunctions and delays. Some provisions have been blocked entirely, while others remain in legal limbo. Covered entities should proceed with caution and watch for updated federal guidance.
HIPAA Reproductive Health Attestation Requirement Overturned
A 2024 final rule required HIPAA-covered entities to obtain a signed attestation before disclosing protected health information related to reproductive health care. On June 18, 2025, a federal court invalidated this requirement nationwide. However, separate updates to the HIPAA Notice of Privacy Practices—unrelated to reproductive health—remain in effect and must be implemented by February 16, 2026.
Mental Health Parity Certification Delayed
A final rule issued in September 2024 would have required fiduciary certification as part of mental health parity compliance for 2025 plan years. That rule is now on hold following a lawsuit and subsequent announcement from federal agencies suspending enforcement for at least 18 months. Employers should continue maintaining written analyses of nonquantitative treatment limitations as required by the statute.
Emerging Compliance Areas to Watch
Several areas are expected to impact future notice obligations. CFOs and HR leaders should stay ahead of these potential requirements.
Health Plan Transparency
On February 25, 2025, President Trump issued an executive order directing federal agencies to enhance price transparency in health care. Upcoming regulatory changes may include the required disclosure of actual prices, standardized reporting formats, and new enforcement strategies. Employers should continue to rely on their carriers or TPAs for support but remain informed as rules evolve.
Pharmacy Benefit Manager Disclosures
States are increasingly regulating PBMs. Some of these laws require PBMs to share pricing and rebate information with health plan fiduciaries, including employers. Employers with self-insured plans may face new responsibilities to distribute or explain this information to plan participants.
Summary of Benefits and Coverage Updates
Federal agencies have announced plans to update the SBC template and related materials, including translated versions and model notices for claims and appeals. While the timing of these updates remains unclear, political shifts may affect their content or release.
Trump Accounts
As part of the new “One Big Beautiful Bill Act” passed on July 4, 2025, employers can now contribute up to $2,500 annually to new tax-advantaged “Trump Accounts” for employees’ children. Employers that choose to implement these accounts must adopt a formal plan and prepare to disclose the program to employees. The IRS is expected to issue additional guidance.
What Employers Should Do Now
Staying compliant in a shifting regulatory environment requires proactive attention. Employers should:
- Review and update all required notices using the latest federal models
- Adjust internal processes in response to new ACA reporting rules
- Monitor federal and state legal developments that may affect compliance
- Prepare for emerging notice requirements related to transparency and plan features
At McConkey, we are here to help you interpret these developments and assess how they affect your health plan strategy. Reach out to your McConkey advisor to ensure your notices and processes are up to date and aligned with the latest federal requirements.
