To get ready for open enrollment, employers who sponsor group health plans should be aware of compliance changes affecting their plan designs for the 2025 plan year. These changes include inflation-adjusted limits under the Affordable Care Act (ACA), new guidance for preventive services, and updates to Health FSAs, HSAs, HDHPs, and more.
Plan Design Changes
ACA Affordability Standard
The ACA requires applicable large employers (ALEs) to offer affordable, minimum-value coverage. For 2025, the affordability threshold increases to 9.02% of household income. Employers should ensure their health plans meet this updated standard and consider using one of the IRS affordability safe harbors (W-2, rate of pay, or federal poverty line).
Out-of-Pocket Maximum Limits
- ACA limit for 2025: $9,200 (self-only) / $18,400 (family)
- HDHP limit for 2025: $8,300 (self-only) / $16,600 (family)
Preventive Care Benefits
Plans must cover the latest recommended preventive services without cost-sharing. New services for 2025 include screenings for anxiety disorders in adults, including pregnant and postpartum patients.
Health FSA Contributions
The 2025 limit on employee pre-tax Health FSA contributions increases to $3,300. Employers must ensure contributions do not exceed this amount and communicate this limit during open enrollment.
HDHP and HSA Limits
| Limit Type | 2024 | 2025 | Change |
|---|---|---|---|
| HSA – Self-only | $4,150 | $4,300 | + $150 |
| HSA – Family | $8,300 | $8,550 | + $250 |
| Catch-up (55+) | $1,000 | $1,000 | No change |
| HDHP Deductible – Self | $1,600 | $1,650 | + $50 |
| HDHP Deductible – Family | $3,200 | $3,300 | + $100 |
| HDHP Max OOP – Self | $8,050 | $8,300 | + $250 |
| HDHP Max OOP – Family | $16,100 | $16,600 | + $500 |
Expiration of HDHP Design Flexibility
For plan years beginning in 2025, HDHPs can no longer waive deductibles for:
- COVID-19 testing and treatment
- Telehealth or remote services (except preventive care)
EBHRA Contribution Limit
The EBHRA contribution cap increases to $2,150 for 2025. Employers should determine their contribution strategy and communicate the amount to employees.
Mental Health Parity: NQTL Comparative Analysis
Plans must maintain an updated comparative analysis for nonquantitative treatment limitations (NQTLs) on mental health and substance use disorder benefits. Employers should confirm their third-party administrators are compliant.
Prescription Drug Coverage & Medicare Part D
Confirm whether prescription drug benefits qualify as creditable for Medicare Part D in 2025. Employers may continue using the simplified method for this determination.
Open Enrollment Notices
Employers should include the following notices with their open enrollment materials:
- Summary of Benefits and Coverage (SBC) – Required at open enrollment; use the federal template.
- Medicare Part D Notice – Creditable or noncreditable status must be communicated annually before Oct. 15.
- CHIP Notice – Required for employees in states offering premium subsidies for employer coverage.
- Initial COBRA Notice – Must be given within 90 days of plan enrollment.
- SPD & SMM – Summarize plan design changes.
- Patient Protections Notice – Required if plan restricts provider selection.
- Grandfathered Plan Notice – Include if applicable.
- HIPAA Special Enrollment Notice – Disclose rights during open enrollment or enrollment events.
- HIPAA Privacy Notice – Provide at enrollment and every 3 years (for self-insured plans).
- WHCRA Notice – Required annually regarding mastectomy-related coverage.
- SAR – Required for plans filing Form 5500 (unfunded plans exempt).
- Wellness Program Notices – Include HIPAA and ADA notices if applicable.
- ICHRA Notice – Must be sent 90 days before plan year starts if offering an ICHRA.
Employers should verify their notices are current, use model language where available, and distribute in a timely manner during open enrollment season.
This Compliance Overview is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice. © 2024 Zywave, Inc. All rights reserved.