Many people see the start of a new year as a time to refresh and renew themselves. For covered entities under HIPAA, which include group health plans, it’s also time to refresh and renew your HIPAA Notice of Privacy Practices (Privacy Notice) to address the changes made to the Confidentiality of Substance Use Disorder (SUD) Patient Records regulations at 42 CFR part 2 (Part 2). The deadline for updating Privacy Notices to reflect these amendments is February 16, 2026.

The high cost of GLP-1 weight loss drugs has significantly affected employer prescription drug spending over the past year, leading many organizations to limit or even eliminate coverage. These unexpected costs have created challenges for employers balancing plan affordability with employee access.

The legal landscape for pharmacy benefit managers (PBMs) continues to shift as states pass new laws and courts weigh in on how those laws interact with federal ERISA requirements. These developments are creating new challenges for self-funded health plans trying to stay compliant.

We recognize that many companies sponsor ERISA welfare benefit plans and will soon be undergoing their open enrollment process and issuing related participant communications. To assist with that process, we have prepared an Automatic Participant Disclosures Checklist for use during open enrollment and throughout the plan year. Note that some of these disclosures may be delivered electronically under certain circumstances.