Forms 1095-B and 1095-C: Which Must Employers Provide?
ACA reporting obligations depend on employer size and plan funding:
- Form 1095-C: Required for Applicable Large Employers (50+ full-time equivalents) to report offers of coverage, plus actual enrollment (Part III) if self-funded.
- Form 1095-B: Reports actual minimum essential coverage enrollment, typically issued by insurance carriers for fully insured plans or non-ALEs with self-funded plans.
Employers may fulfill federal employee distribution via a compliant website notice offering forms upon request, though mandatory IRS filing and applicable state deadlines still apply. Click here to learn more.
Your PBM Countdown Has Started: DOL Finalizes Fee-Disclosure Rule
The Department of Labor has finalized a sweeping fee-disclosure rule for pharmacy benefit managers, significantly expanding transparency for self-insured employer plans. While the rule applies to plan years starting on or after July 1, 2027, plans renewing that day will require disclosures as early as April 2, 2027. The regulations mandate clear reporting on spread pricing, retained manufacturer payments, and annual audit rights. With upcoming first-quarter RFPs, employers should evaluate affected contracts and engage PBMs early. Click here to read more.
Spotlight on Wellness: Free Nutrition Workshops with The Food Trust
Many employer health plans include annual “use-it-or-lose-it” wellness dollars, and our non-profit partner, The Food Trust, is expanding options for your workplace. As they prepare to qualify for future plan-sponsored wellness funding, they are currently offering a limited number of free, one-hour, in-person nutrition Lunch & Learns through the end of 2026. Led by experienced educators, sessions cover practical meal planning, hands-on cooking, and trending wellness topics.
Contact Catharine Frazier at cfrazier@thefoodtrust.org before year-end to reserve a free workshop for your team.
Priority Update: Midsize Product Discontinuance for Horizon BCBSNJ
Effective March 1, 2027, Horizon BCBSNJ will discontinue several legacy midsize Direct Access, PPO, and POS plans across the M, P, O, and Z series. Impacted groups will not be automatically transitioned to a replacement plan. Employers must proactively select an alternative—such as the new Q-Series or expanded Level-Funded options—prior to renewal. Formal notices will be issued approximately 90 days before renewal dates, and our team is ready to guide you through your options.
Independence Blue Cross & Jefferson Health Network Update
Independence Blue Cross (IBX) is currently negotiating contract renewal terms with Jefferson Health ahead of their December 31, 2026 agreement expiration. While discussions over proposed rate increases continue, there is no immediate change to member coverage. Jefferson Health facilities and providers remain fully in-network through the end of the year, and emergency care will not be impacted. IBX is actively working toward an agreement to balance broad access with affordable care.
Enhancing the Member Experience: IBX Digital Upgrades in 2026
Independence Blue Cross launched more than 50 member portal and app enhancements in 2026, boosting its App Store rating to 4.3 stars. Key improvements include direct digital tracking for medical prior authorizations, a unified single-form claims submission process with real-time tracking, and a navigation tool to connect members with in-network behavioral health providers.
Compliance Corner: Two Down, a Few to Go: Closing Out 2026 Compliance
With Medicare Part D notices and extended Form 5500 filings behind us, fourth-quarter attention shifts to year-end compliance obligations. As open enrollment and renewal deadlines converge, plan sponsors must navigate several critical remaining milestones:
- Dec. 15: Distribute Summary Annual Reports (SARs) to participants if an extended Form 5500 was filed.
- Dec. 31: Submit the annual Gag Clause Prohibition Compliance Attestation (GCPCA) to CMS/DOL.
- Before Jan. 1: Issue required annual participant notices (CHIP, WHCRA, Medicare Part D/SBCs) and Summaries of Material Modifications (SMMs), complete ACA employee data aggregation for Forms 1094-C/1095-C, and prepare the online CMS Part D disclosure.