Employer Health Mandates and Medicare Part D Compliance

The “Benefits Buzz Newsletter October 2025” from an unspecified source addresses critical compliance deadlines and financial adjustments related to employer-sponsored health coverage. One section explains that group health plan sponsors must provide Medicare Part D creditable coverage disclosure notices to Medicare-eligible individuals and the Centers for Medicare and Medicaid Services before October 15, 2025, which marks the beginning of the annual Medicare enrollment period. Separately, the source outlines that Applicable Large Employers (ALEs) will face significantly increased penalties in 2026 under the Affordable Care Act’s “pay-or-play” mandate for failing to offer affordable, minimum-value health coverage to their full-time employees. Specifically, the source details the two main penalty calculations, Section 4980H(a) and Section 4980H(b), noting their substantial increase in dollar amount for the coming year.

HHS Catastrophic Coverage Hardship Exemption Guidance

The provided guidance from the U.S. Department of Health and Human Services (HHS) expands upon existing hardship exemption policies for catastrophic health coverage. This new guidance, released on September 4, 2025, aims to help individuals access affordable health plans, particularly in anticipation of premium increases for the 2026 plan year. Specifically, it clarifies that individuals who are ineligible for advance payments of premium tax credits or cost-sharing reductions due to their projected household income may qualify for a hardship exemption to enroll in catastrophic plans. These plans are characterized by low monthly premiums and high deductibles, designed to protect against significant medical costs. The guidance does not introduce new regulations but offers an additional example of a hardship, with applications becoming available starting November 1, 2025.

For more information on this guidance, give us a call at (520) 721-4848.