EMPLOYEE BENEFITS BLOG

IRS Releases 2026 Limits for HSAs and Excepted Benefit HRAs

by Evan Walters, Samuel Hamer, Edward Froelich, Michael Scarduzio and Matthew J. Blaney | Jun 10, 2025 | Employee Benefits, Health and Welfare Plans

On May 19, 2025, the Internal Revenue Service (IRS) released Internal Revenue Bulletin 2025-21. It includes Revenue Procedure 2025-19, which provides the 2026 inflation-adjusted amounts for health savings accounts (HSAs) as determined under Code § 223, as well as the maximum amount that may be made newly available for excepted benefit health reimbursement arrangements (HRAs) under Code § 54.9831-1(c)(3)(viii). Revenue Procedure 2025-19 is effective for HSAs for the 2026 calendar year and for excepted benefit HRAs beginning in 2026.

Learn more about other new IRS guidance in this Weekly IRS Roundup published by McDermott’s Tax Group.

Trump Administration Takes Steps to Enhance Healthcare Price Transparency

by Jeffrey Davis and Leigh Feldman | Jun 5, 2025 | Employee Benefits, Health and Welfare Plans

In May, the Trump administration issued guidance and requests for information (RFIs) to enhance healthcare price transparency, focusing on both hospitals and health plans. For hospitals, the guidance reiterates the need to provide actual dollar amounts for payer-specific negotiated charges in machine-readable files (MRFs) rather than percentages, and it seeks input on improving the accuracy and completeness of MRF data. For health plans, the RFI addresses concerns about file size and data integrity, and it explores the implementation of net prices for covered prescription drugs, indicating that the administration plans to issue revised schemas and may pursue further transparency rulemaking.

Read more here.

One Big Beautiful Bill Act Has Compensation & Benefits Impacts for Nonprofit Health Systems

by Travis Jackson, Robert C. Louthian, III and Kristen O'Brien | Jun 3, 2025 | Employee Benefits, Executive Compensation, Health and Welfare Plans

The US House of Representatives passed its One Big Beautiful Bill Act on May 22, 2025 (the Act), but nonprofit health systems may not find much about the Act that’s attractive. If passed by the US Senate and signed into law, the Act would threaten already thin operating margins at nonprofit hospitals and health systems by expanding the executive compensation excise tax, taxing parking, and similar employee benefits.

Read more here.

An Update on NAIC’s Consideration of AI Model Law for Insurers

by Amber Adair, H. Michael Byrne and Zachary (Zach) Couger | May 29, 2025 | Privacy and Data Security

The National Association of Insurance Commissioners’ (NAIC) Big Data and Artificial Intelligence (H) Working Group released a request for information (RFI) to explore the potential drafting of a model law to regulate insurers’ use of artificial intelligence (AI) systems. The RFI asks stakeholders to provide comments on whether uniform statutory requirements for AI are needed in the insurance industry.

Read more here.

“Big, Beautiful Bill”: Federal Tax Bill Would Restrict the Employee Retention Credit

by Shawn O’Brien, Samuel Hamer and Michael Scarduzio | May 27, 2025 | Employee Benefits, Fiduciary and Investment Issues

A new federal tax bill under consideration in the US House of Representatives proposes major changes to the Employee Retention Credit (ERC), including disallowing claims made after January 31, 2024 – even if they were filed before the official deadlines in April 2024 and 2025. It would also extend the Internal Revenue Service’s statute of limitations for assessing ERC-related amounts to six years, raising uncertainty for taxpayers with pending or previously approved claims.

Read more here.