Blog

CMS Finalizes Two Significant Medicare Part D Creditable Coverage Changes for 2027

National Employee Benefits Practice — Wed, 08 Apr 2026 15:30:55 GMT

Summary: On April 2, 2026, the Centers for Medicare and Medicaid Services (CMS), the federal agency governing Medicare, released a final rule for plan years beginning in calendar year 2027 impacting the Medicare Part D prescription drug benefit program (“final rule”). Click here for a CMS fact sheet summarizing the final rule.

Employers sponsoring group health plans should pay attention to two specific provisions within the final rule, outlined below:

Excluding account-based plans from the Notice of Creditable Coverage disclosure requirement for the following account-based plans:
- Health reimbursement arrangements (HRAs), including individual coverage HRAs (ICHRAs),
- Flexible spending accounts (FSAs), and
- Health savings accounts (HSAs))
Retiring the use of the current simplified determination method and codifying the revised simplified determination method, starting in 2027, for creditable coverage determination purposes.

Read on for more information and employer plan sponsor considerations.

Group Health Plan Fiduciary Lawsuit Survives Motion to Dismiss

National Employee Benefits Practice — Wed, 08 Apr 2026 14:07:34 GMT

Summary: A federal judge in New York recently allowed certain ERISA claims against an employer group health plan sponsor for alleged pharmacy benefit mismanagement to proceed past a motion to dismiss.

Read on for more information and employer group health plan sponsor considerations.

2026 Compliance Reminder: Upcoming Form 5500 Deadline for Calendar Year Plans

National Employee Benefits Practice — Wed, 25 Mar 2026 12:42:04 GMT

Employers sponsoring health and welfare benefit plans^[1] subject to the Employee Retirement Income Security Act of 1974 (ERISA) should take note of the upcoming Form 5500 filing deadline on July 31, 2026 for calendar year plans.

Shaping Transparency in Today's Pharmacy Benefits Marketplace

Brown & Brown Consulting — Tue, 24 Mar 2026 19:10:10 GMT

True transparency in the pharmacy benefit marketplace is more than publishing numbers or simplifying reports. It requires clear contractual, financial, and clinical accountability so plan sponsors can understand what drives their costs and what value they receive. When done correctly, transparency reduces the influence of artificial or undisclosed pricing structures and encourages a market focused on full disclosure of Pharmacy Benefit Management (PBM) revenue streams, aligned financial incentives, and clear line of sight into actual drug costs. The industry is moving toward more transparent models due to state and federal pressures. Our viewpoint is that the regulations should be a floor and not a ceiling on providing true transparency.

Why Property Insurance for Dental Practices is Still Rising in 2026

Kyle Wallace, Managing Director, Dental Practice — Fri, 13 Mar 2026 20:43:46 GMT

If your dental practice’s recent property renewal was unexpectedly high, you’re not alone. Premiums are rising, water‑damage deductibles are climbing, and some long‑time carriers are declining to renew, sending practices to the surplus lines market.

Another Season is Almost Here…Another Compliance Deadline Looms: RxDC Reporting

National Employee Benefits Practice — Thu, 05 Mar 2026 14:42:11 GMT

Summary: Spring is almost here, and with a new season comes a new compliance deadline looming for employers sponsoring group health plans: RxDC reporting for the 2025 reference year.

The Centers for Medicare and Medicaid Services (CMS) recently released updated RxDC reporting instructions for the 2025 reference year, which is due on June 1, 2026.

The updated instructions confirm no major changes from the previous version of RxDC reporting instructions other than updating the reference year from 2024 to 2025.

Read on for a general overview of RxDC reporting and employer group health plan sponsor next steps ahead of the June 1, 2026 deadline.

2026 Reminder: San Francisco HCSO Upcoming Reporting Deadline

National Employee Benefits Practice — Mon, 02 Mar 2026 13:44:58 GMT

Summary: Employers covered by the San Francisco Health Care Security Ordinance (HCSO) are required to submit the 2025 HCSO Annual Reporting Form by Friday, May 1, 2026.

The 2025 HCSO Employer Annual Reporting Form will be available on April 1, 2026, at this webpage. Covered employers who fail to make a timely submission of the HCSO Annual Reporting Form may be subject to a penalty of $500 per quarter.

Read on for more information and employer next steps.

How Corporate-Owned Life Insurance Supports Executive Benefits in 2026

Scott Richardson, Managing Director, Executive Benefits — Wed, 25 Feb 2026 20:18:46 GMT

In the competitive landscape of enterprise leadership, retaining top talent requires more than a standard salary. It demands robust benefits packages, often in the form of non-qualified deferred compensation or supplemental retirement plans. For financial institutions and other enterprises, Corporate-Owned Life Insurance (COLI) serves as the silent engine funding these commitments. (Variations specific regulated entities are Bank-Owned Life Insurance or BOLI and Insurance Company Owned Life Insurance or ICOLI.)

Employer Autism Spectrum Disorder Care Strategy

Brown & Brown Consulting — Mon, 23 Feb 2026 15:00:03 GMT

Employers seeking to deliver truly comprehensive benefits can no longer afford to overlook autism spectrum disorder (ASD) and its growing impact on their workforce. ASD prevalence has risen sharply. In 2022, approximately one in 31 children eight years of age was diagnosed, compared with one in 150 in 2000, representing a nearly fourfold increase.^[1] Yet access to care has not kept pace. There are roughly 82,000 board-certified behavioral analysts nationwide, but many other qualified providers (i.e., Developmental-Behavioral Pediatricians, Child Psychiatrists, and Child Neurologists) remain scarce or out of network for employees and their families.^[2]

New Jersey Family Leave Act Expands in July 2026

National Employee Benefits Practice — Fri, 20 Feb 2026 19:52:48 GMT

Summary: In one of his last acts before leaving office, outgoing New Jersey (NJ) Governor Phil Murphy signed Assembly Bill (AB) 3451 on January 17, 2026, amending the New Jersey Family Leave Act (NJ FLA) to apply to smaller employers and ease employee eligibility requirements.

AB 3451 also expands job protection for employees receiving benefits under NJ temporary disability insurance (TDI) and NJ family leave insurance (FLI) programs. The amendments in AB 3451 take effect on July 17, 2026.

Read on for more details and employer next steps ahead of the July 17, 2026 effective date.