As you prepare for the 2026 open enrollment season, you are likely facing a regulatory landscape that feels more complex and high-stakes than ever before. Between evolving ACA thresholds, the delayed but now-critical SECURE 2.0 requirements, and a patchwork of state-level paid leave mandates, the risk of an accidental oversight is significant. These compliance gaps don't just lead to administrative headaches; they can result in substantial financial penalties and a breakdown in trust with your most valuable asset: your employees.

We understand that you need a bridge between these complex federal mandates and a smooth, stress-free administration process. At Plan Professionals, we act as your trusted advisor, translating dense legal requirements into actionable strategies. We believe that compliance shouldn't be a source of anxiety, but rather a foundation for a robust, cost-effective, and reassuringly thorough benefits program.

The following checklist is designed to help you navigate the 2026 compliance landscape with confidence, ensuring your organization remains fully protected while delivering the coverage your team deserves.

1. ACA Reporting & Affordability: The Compliance Foundation

For 2026, the Affordable Care Act (ACA) remains the primary focus for any Applicable Large Employer (ALE). While the core requirements are familiar, the thresholds and reporting methods continue to evolve. We prioritize precise tracking to ensure you never fall below the required benchmarks.

Key Actions for Your 2026 Strategy:

• Verify ALE Status: We recommend documenting your full-time equivalent (FTE) count now to confirm your status for the upcoming year. If you have crossed the 50-FTE threshold, your reporting obligations change significantly.
• Test for Affordability: The IRS affordability threshold is a moving target. For 2026, ensure your self-only coverage premiums do not exceed the set percentage of an employee’s household income. We utilize IRS safe harbors: such as the Form W-2 or Rate of Pay methods: to provide you with certainty.
• Electronic Filing Mandate: Remember that the IRS now requires electronic filing for almost all employers. If you are still relying on paper processes, we can help transition your reporting to our technology and compliance platforms to avoid rejected filings.
• Confirm Minimum Value: Your plans must cover at least 60% of the total allowed cost of benefits. We analyze your plan designs to ensure they meet this "Minimum Value" standard, protecting you from 4980H(b) penalties.

By leadings with these proactive steps, we ensure your health plan remains a compliant sanctuary for your employees rather than a liability for your business.

2. PBM Transparency & The End of "Gag Clauses"

Transparency is no longer an optional "best practice": it is a legal requirement under the Consolidated Appropriations Act (CAA). If your current pharmacy benefit manager (PBM) is keeping you in the dark regarding rebates or negotiated rates, you may be in violation of federal law.

Your Transparency Checklist:

• Remove Gag Clauses: We review your PBM and carrier contracts to ensure no "gag clauses" exist. These illegal clauses prevent you from seeing the actual cost data and quality metrics of the services you pay for.
• Submit Annual Attestations: All plan sponsors must submit a "Gag Clause Prohibition Compliance Attestation" (GCPCA) to CMS annually. We assist our clients in ensuring this is submitted accurately and on time, typically by the December 31 deadline.
• Machine-Readable Files (TiC): Ensure your "Transparency in Coverage" (TiC) files are publicly accessible and updated every 30 days. Starting February 2, 2026, these files must comply with schema version 2.0. We verify that your TPA or carrier is hosting these correctly.
• Rx Cost Reporting: We help you gather the necessary data for prescription drug cost reporting, identifying where your spend is going and how rebates are being applied to your bottom line.

Our approach to cost containment is built on this radical transparency. We believe you should know exactly where every dollar of your premium is going.

3. SECURE 2.0: Retirement Requirements Are Now Live

If 2025 was the year of preparation for SECURE 2.0, 2026 is the year of execution. Several major provisions that were once optional are now becoming mandatory for many plans.

Mandatory Retirement Updates:

• Automatic Enrollment & Escalation: For many new 401(k) or 403(b) plans established after the act’s passage, automatic enrollment is now a requirement. We check your plan documents to ensure your default contribution rates and automatic escalation features are compliant.
• Long-Term Part-Time Employees: You must now allow employees who work between 500 and 999 hours over two consecutive years to participate in your retirement plan. We help you audit your payroll records to identify these eligible team members.
• Roth Catch-Up Contributions: For highly compensated employees (earning over $145,000, indexed for 2026), catch-up contributions must be made on a Roth (after-tax) basis. We coordinate with your recordkeepers to ensure your payroll system can handle this split.
• Increased RMD Age: We verify that your plan administration reflects the updated Required Minimum Distribution (RMD) ages, preventing costly distribution errors for your senior employees.

We view retirement benefits as a vital tool for long-term retention. By ensuring these plans are compliant, we help you build a more secure future for your workforce.

4. ICHRA & Alternative Models: Flexibility with Compliance

For many small to mid-sized businesses, the traditional group health model is becoming cost-prohibitive. The Individual Coverage Health Reimbursement Arrangement (ICHRA) is a powerful alternative, but it comes with its own unique compliance hurdles.

ICHRA Compliance Essentials:

• Affordability Testing: Just like traditional plans, an ICHRA must be "affordable." We calculate your HRA contribution amounts against the lowest-cost silver plan in the local exchange to ensure you meet ACA standards.
• Class Consistency: You cannot "cherry-pick" who gets an ICHRA. We help you define legal employee classes: such as hourly vs. salaried or geographic locations: to ensure your offering is non-discriminatory.
• Notice Requirements: You must provide an ICHRA notice to employees at least 90 days before the plan year begins. We provide the templates and distribution strategies to ensure every employee is informed of their rights and the impact on their premium tax credits.
• Enrollment Verification: We establish the "substantiation" processes needed to verify that employees are actually enrolled in individual coverage before reimbursements are issued.

Whether you choose a traditional PPO or an innovative ICHRA, we design tailored solutions that meet your specific needs and budget.

5. The State-Level Challenge: Paid Leave & Mandates

Operating in multiple states adds a layer of complexity that can overwhelm even the most experienced HR teams. In 2026, several states are expanding their paid family and medical leave (PFML) programs and sick leave requirements.

Staying Locally Relevant:

• New State Programs: States like Minnesota and Maryland are seeing significant updates to their leave frameworks in the 2025-2026 window. We provide the geographic expertise to help you track which laws apply to your remote and local workers.
• Policy Alignment: We review your employee handbook to ensure your PTO and sick leave policies don't conflict with local "use-it-or-lose-it" prohibitions or accrual mandates.
• Payroll Integration: We work with providers like Sure Payroll to ensure your state-level leave taxes are being calculated and withheld correctly, preventing year-end tax surprises.

Your Path to a Seamless Open Enrollment

Compliance is not a one-time event; it is an ongoing commitment to excellence and ethics. As your long-term partner, Plan Professionals is here to ensure that your 2026 open enrollment is more than just a deadline: it's an opportunity to strengthen your organization.

We invite you to reach out for a comprehensive review of your current plan. Whether you are looking for a more holistic approach to insurance consulting or simply need a second set of eyes on your compliance checklist, we are ready to assist. Let’s make 2026 the year your benefits program becomes a true strategic advantage.

Contact us today to schedule your compliance audit.